Delhi HC Quashes 2015 Maggi Noodles Cases Over Lead Content

The Delhi High Court has quashed two criminal complaints related to the 2015 Maggi Noodles controversy, along with the trial court's summoning orders and all subsequent proceedings. Justice Madhu Jain held that continuing the prosecutions would amount to an abuse of the process of law, as the foundational basis of the cases had substantially eroded.

The petitions were filed by Dharmendra Hansraj Kotak and others, challenging the criminal complaints, the summoning orders dated November 6, 2015 and January 11, 2016, and the proceedings pending before the trial court. The Court exercised its inherent powers under Section 482 of the Code of Criminal Procedure to set aside these complaints.

The cases originated from a nationwide sampling exercise in May 2015, during which Delhi's Food Safety Department collected samples of Maggi Noodles. The Food Analyst reported that the lead content in the masala tastemaker exceeded the permissible limit of 2.5 parts per million (ppm). One complaint also alleged misbranding due to the 'No Added MSG' declaration. Criminal complaints were subsequently filed under the Food Safety and Standards Act, 2006.

The petitioners argued that the prosecutions rested entirely on Food Analyst reports that had lost legal validity after the Bombay High Court set aside the nationwide ban on Maggi Noodles. That Court had held that laboratories conducting analysis under the Act must be both NABL-accredited and notified under Section 43, and found that the laboratories in question did not meet these requirements.

Following the Supreme Court's directions, fresh testing was carried out by accredited laboratories and later by the Central Food Technological Research Institute (CFTRI) in Mysuru, a notified Referral Food Laboratory. These tests found the lead content to be within permissible limits. The Supreme Court subsequently directed that the CFTRI report should form the basis for adjudication before the National Consumer Disputes Redressal Commission (NCDRC). The NCDRC ultimately dismissed the complaint filed by the Union of India.

The State opposed the petitions, arguing that the complaints had been filed after following statutory procedure and that the petitioners had not exercised their right to seek referral analysis at the relevant time. It also contended that the later judicial decisions regarding the nationwide ban did not automatically invalidate individual criminal cases arising from samples collected in Delhi.

Examining the record, the High Court noted that the prosecutions were based exclusively on the Food Analyst reports declaring the samples 'unsafe' due to alleged excess lead. The Court observed that the controversy had undergone extensive judicial scrutiny, including the Bombay High Court verdict and the Supreme Court's directions for fresh scientific evaluation. Once the CFTRI report found lead within permissible limits and the NCDRC dismissed the consumer complaint, the evidentiary value of the original Food Analyst reports stood substantially diluted.

The Court concluded that allowing the prosecutions to continue would force the petitioners to undergo a protracted criminal trial despite the erosion of the prosecution's foundation. It therefore quashed the complaints and all consequential proceedings.

This judgment brings closure to the criminal cases arising from the 2015 Maggi Noodles sampling in Delhi. It underscores the importance of relying on scientifically credible and legally compliant laboratory testing in food safety enforcement, and the role of courts in preventing abuse of process when the evidentiary basis of a prosecution collapses.