Supreme Court Upholds Regulation of Rice Bran as Essential Commodity — Clarifies Definition of Foodstuff.

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Case Note & Summary

The dispute arose from a challenge to the Haryana Rice Bran (Distribution and Price) Control Order, 1967, which regulated the sale of rice bran. The appellants, dealers in rice and rice bran, contended that rice bran was not an essential commodity under the Essential Commodities Act, 1955, and thus the regulation was invalid. The High Court dismissed their writ petition, leading to an appeal in the Supreme Court. The core legal issue was whether rice bran could be classified as an essential commodity. The court analyzed the definitions provided in the Act, particularly focusing on the terms 'foodstuff' and 'cattle fodder.' It concluded that rice bran, being a by-product of rice milling and commonly used as feed for poultry and cattle, fell within the definition of foodstuff. The court emphasized that the term 'foodstuff' should not be limited to human consumption but should include any substance that sustains life for any living being. The court referenced dictionary definitions to support its reasoning, asserting that the regulation of rice bran was justified under the Act. The appeal was dismissed, affirming the High Court's decision without costs.

Headnote

A) Essential Commodities Act - Definition of Essential Commodity - Rice Bran as Foodstuff - Essential commodity includes rice bran as it is a foodstuff under section 2(a)(v) of the Act - The court held that rice bran, commonly used as poultry and cattle feed, is a foodstuff and thus an essential commodity, allowing regulation under section 3. (Paras 198-200)

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Issue of Consideration

Whether rice bran qualifies as an essential commodity under the Essential Commodities Act, 1955.

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Final Decision

The Supreme Court dismissed the appeal, affirming the High Court's ruling that rice bran is an essential commodity under the Essential Commodities Act, 1955, allowing for its regulation.

Law Points

  • Essential Commodities Act
  • definition of essential commodity
  • regulation of foodstuffs
  • interpretation of foodstuff
  • cattle fodder
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Case Details

1982 LawText (SC) (02) 25

Civil Appeal No. 1099(N) of 1972

1982-02-05

Chandrachud, Y.V.

1982 AIR 798, 1982 SCR (3) 196, 1982 SCC (1) 610, 1982 SCALE (1) 89

B.P. Maheshwari, Suresh Sethi, K.G. Bhagat, M.N. Shroff

Sat Pal Gupta & Anr.

State of Haryana & Anr.

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Nature of Litigation

Challenge to the validity of a control order regulating rice bran.

Remedy Sought

Appellants sought to invalidate the regulation of rice bran as an essential commodity.

Filing Reason

Claimed rice bran was not an essential commodity under the Act.

Previous Decisions

High Court dismissed the writ petition challenging the control order.

Issues

Whether rice bran is an essential commodity under the Essential Commodities Act, 1955.

Submissions/Arguments

Appellants argued rice bran is not an essential commodity. Respondents maintained rice bran is a foodstuff and essential commodity.

Ratio Decidendi

Rice bran is classified as a foodstuff under the Essential Commodities Act, 1955, allowing for its regulation as an essential commodity.

Judgment Excerpts

Rice bran being a 'foodstuff' within the meaning of section 2(a)(v) of the Act, it is an essential commodity. Cattle feed and poultry feed are food to the cattle and the poultry, and therefore they are foodstuffs.

Procedural History

The appellants filed a writ petition under Article 226 in the High Court, which was dismissed. The appellants then appealed to the Supreme Court.

Acts & Sections

  • Essential Commodities Act, 1955: 2(a), 3
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