Designated laboratory report controls food safety compliance, while further reprocessing may be allowed before release

Where a prior judicial direction requires testing by a designated laboratory for compliance with food standards, the report of that laboratory governs and is not displaced merely by a contrary report from another laboratory. The material must satisfy the prescribed standards on retesting by the same designated laboratory before it can be released. If the reprocessed goods still do not meet the required norm, a further opportunity may be granted to reprocess the consignment and present a fresh sample for examination. Release for human consumption remains barred until the statutory standard is met.

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Issues: (i) Whether the report of the Central Food Laboratory, Mysore, could be set aside on the basis of a contrary report obtained from another laboratory; (ii) Whether the petitioner should be granted a further opportunity to reprocess the imported material and have it retested by the same laboratory.

Issue (i): Whether the report of the Central Food Laboratory, Mysore, could be set aside on the basis of a contrary report obtained from another laboratory.

Analysis: The earlier judicial direction had specifically required testing of the reprocessed goods by the Central Food Laboratory, Mysore, for determining whether the goods conformed to the standards prescribed under the Prevention of Food Adulteration Rules, 1955. In that situation, the result of the designated laboratory could not be displaced merely because another laboratory had given a different result on the same material.

Conclusion: The contrary report from another laboratory could not override the report of the Central Food Laboratory, Mysore.

Issue (ii): Whether the petitioner should be granted a further opportunity to reprocess the imported material and have it retested by the same laboratory.

Analysis: The earlier order was understood to ensure that the consignment would not be released until it satisfied the prescribed standards on testing by the designated laboratory. Since the reprocessed goods had still not met the required standard on the first attempt, a further opportunity was warranted so that the material could be brought within the prescribed norms and placed again for examination.

Conclusion: The petitioner was granted a further opportunity to reprocess the material and present a fresh sample for testing by the Central Food Laboratory, Mysore.

Final Conclusion: The writ petition was disposed of with directions permitting further reprocessing and retesting, while the goods were not to be released for human consumption unless the prescribed standard was satisfied.

Ratio Decidendi: Where a prior judicial order mandates testing by a particular laboratory for compliance with statutory standards, the report of that designated laboratory governs, and a further opportunity may be granted to enable compliance where the goods still do not meet the prescribed norm.

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