Court Overturns Previous Rulings, Finds No Misleading Information in "Maha Value" Labeling
In a significant ruling, the Uttarakhand High Court has overturned previous judgments against PepsiCo India Holdings Private Limited regarding allegations of misbranding under the Food Safety and Standards Act, 2006. The High Court, presided over by Justice Ravindra Maithani, found that the prosecution failed to establish that the label "Maha Value" on PepsiCo's product was false or misleading.
The case originated from a 2015 inspection by the Food Safety Officer in Garhwal, where packets of "Lahar Aloo Bhujia" were alleged to be misbranded due to the use of the phrase "Maha Value." The Adjudicating Officer had initially imposed a penalty of Rs. 1.5 lakhs on PepsiCo, a decision upheld by the Food Safety Appellate Tribunal in 2024.
In its defense, PepsiCo argued that the phrase "Maha Value" merely indicated the quantity, compliant with the Legal Metrology Act, 2009, and the associated rules, and did not pertain to any misleading information about the product's quality or nutritional value. The High Court noted that the public analyst's report lacked reasoning or specifics on how the label was misleading, thus failing to meet the burden of proof required for misbranding under the Food Safety and Standards Act.
Referring to similar cases and legal precedents, Justice Maithani emphasized that the responsibility to prove misleading information lay with the prosecution, which did not address the compliance of the label with legal metrology laws. The Court ruled that without evidence of false or deceptive claims, prosecution and penalties could not be justified.
Consequently, the High Court set aside the previous judgments and penalties imposed on PepsiCo, underscoring the necessity for detailed and reasoned findings in misbranding allegations. The verdict is seen as a reaffirmation of stringent standards for evidence in food safety prosecutions.
Bottom line:-
Food Safety and Standards Act, 2006 - Merely writing "Maha Value" on the label of a food product does not amount to misbranding unless it is established that the label contains false or misleading information.
Statutory provision(s): Food Safety and Standards Act, 2006 Section 3(1)(zf)(A)(i), Section 23; Food Safety and Standards (Packaging and Labelling) Regulations, 2011 Regulation 2.3.1; Legal Metrology Act, 2009; Legal Metrology (Packaged Commodities) Rules, 2011.
