Delhi HC Quashes 2015 Maggi Noodles Criminal Cases After Later Scientific Findings Weaken Prosecution

The Delhi High Court has quashed criminal proceedings arising from the 2015 nationwide Maggi Noodles sampling exercise, holding that the prosecutions could not continue after subsequent judicial and scientific developments had substantially weakened their foundation. Justice Madhu Jain observed that forcing the petitioners to face trial despite later findings would amount to an abuse of the court's process.

Background of the Case

The petitions were filed by Dharmendra Hansraj Kotak & Others, challenging criminal complaints initiated under the Food Safety and Standards Act, 2006. The cases related to samples of Maggi Noodles collected in Delhi during May 2015 as part of the nationwide inspection drive. Food Analysts had reported that the lead content in the tastemaker exceeded the prescribed limit, and in one complaint the product was also alleged to be misbranded because of the "No Added MSG" declaration. Based on these reports, complaints were filed and summons were issued by the trial court.

The petitioners argued that the prosecutions had lost their legal basis after later judicial proceedings concerning the same nationwide sampling exercise. They relied on the Bombay High Court's decision setting aside the Maggi ban, subsequent testing by accredited laboratories, and findings of the Supreme Court-directed Referral Food Laboratory, which found the product within the prescribed standards.

Court's Observations

Justice Madhu Jain noted that the criminal complaints were founded entirely on the original Food Analyst reports. However, those reports were later subjected to judicial scrutiny, leading to fresh testing through the Central Food Technological Research Institute (CFTRI), a recognised Referral Food Laboratory, under the supervision of the Supreme Court.

The Court observed:

“Where the very scientific foundation upon which the prosecution rests has undergone subsequent examination through a process supervised by the constitutional courts, the High Court cannot remain oblivious to those developments.”

The judgment further stated that once fresh scientific evaluation had been carried out through a statutory referral laboratory, the evidentiary value of the earlier reports stood considerably diluted. The Court also referred to similar decisions of the Himachal Pradesh and Uttarakhand High Courts, which had quashed prosecutions arising from the same Maggi controversy.

Court's Decision

Allowing both petitions, the Delhi High Court held that continuing the prosecutions would serve no useful purpose because the basis of the complaints had substantially eroded following later judicial and scientific findings.

“The continuation of the impugned complaints would amount to abuse of the process of Court and would not advance the cause of justice,” the Court observed while quashing the criminal complaints, the summoning orders dated November 6, 2015 and January 11, 2016, and all consequential proceedings.

Case Details

Case Title: Dharmendra Hansraj Kotak & Ors. v. State of Delhi & Anr.

Case Number: CRL.M.C. 7013/2022 & CRL.M.C. 328/2023

Judge: Hon'ble Ms. Justice Madhu Jain

Decision Date: 6 August 2026