Strict liability under food adulteration rules: supari is not a permitted fruit-product or flavouring-agent for colouring purposes.

Food adulteration law treats permitted colouring as exceptional, and only the foods expressly covered by Rule 29 may use coal-tar colours. On a common-parlance reading of the rules and Appendix B, supari or betel-nut does not fall within "fruit-products" or "flavouring-agent" for that purpose. The article also states that liability under the scheme is strict, so a bona fide but mistaken interpretation of the rule does not displace the offence or create a defence based on ignorance of law. The statutory classification of the product and the objective meaning of the rule therefore control the legal result.

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Issues: (i) whether supari or betel-nut sold in the case could be treated as a fruit-product or flavouring-agent within Rule 29 so that the use of permitted coal-tar food-colours was not prohibited; (ii) whether a bona fide but erroneous interpretation of the rule entitled the accused to the benefit of doubt.

Issue (i): whether supari or betel-nut sold in the case could be treated as a fruit-product or flavouring-agent within Rule 29 so that the use of permitted coal-tar food-colours was not prohibited.

Analysis: The relevant scheme of the Food Adulteration Rules was read as prohibiting colouring matter except where specifically permitted, and then restricting even permitted coal-tar colours to the foods enumerated in Rule 29. The expression "fruit-products" was construed in its statutory setting and in the context of Appendix B, which showed items such as fruit juice, fruit syrup, fruit squash, fruit beverage, fruit drink, marmalade, fruit chutney, sauce and similar products. Applying a common-parlance understanding and the object of the legislation, supari was held not to answer that description. The alternative suggestion that it was a flavouring-agent was also rejected.

Conclusion: The answer was against the accused; supari was not a fruit-product or flavouring-agent within Rule 29 and the use of the colour amounted to adulteration.

Issue (ii): whether a bona fide but erroneous interpretation of the rule entitled the accused to the benefit of doubt.

Analysis: The offence under the Act was treated as one of strict liability, where the act prohibited by law constituted the offence and mens rea was unnecessary. The Court held that a mistaken view of the law could not substitute for the legal meaning of the rule, and ignorance or misapprehension of the law afforded no defence. The statutory scheme required objective application of the rules rather than the accused's subjective understanding.

Conclusion: The answer was against the accused; no benefit of doubt arose on the basis of a bona fide but incorrect legal interpretation.

Final Conclusion: The conviction was sustained, though the Court directed consideration of remission of the substantive sentence of imprisonment by the appropriate authority.

Ratio Decidendi: In prosecutions under the food adulteration law, the classification of an article for the purposes of permitted colouring must be determined by the statutory context and common parlance, and strict liability applies so that a mistaken personal interpretation of the rule does not negate the offence.

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