The Uttarakhand High Court has quashed a fine of Rs 3 lakh imposed on PepsiCo India Holdings Private Limited, ruling that labeling a packaged food product as 'Maha Value' does not amount to misbranding under the Food Safety and Standards Act, 2006.
Court's Observations
Justice Ravindra Maithani, presiding over a single-judge bench, observed that the prosecution failed to demonstrate that the phrase 'Maha Value' conveys any false or misleading information to consumers. The court emphasized that a product cannot be declared misbranded without concrete reasoning and scientific analysis.
Background of the Case
The case dates back to 2015, when a food safety officer in Pauri Garhwal collected samples of 'Lehar Aloo Bhujia' from a local shop for analysis. A public analyst flagged the product as 'misbranded' solely because the words 'Maha Value' were printed on the corner of the packet. Based on this report, an adjudicating officer imposed a fine of Rs 1.5 lakh each on PepsiCo India and its manufacturing partner, which was later upheld by the Food Safety Appellate Tribunal.
Defense by PepsiCo
The court accepted PepsiCo's consistent defense that 'Maha Value' referred to the product quantity, not its quality. The label was intended to inform buyers that the packet was a larger 'value pack,' a practice aligned with the Legal Metrology Act and its guidelines.
Flawed Proceedings
Justice Maithani noted that the public analyst's report merely cited sections of the law without explaining how the term 'Maha Value' could actually mislead a consumer. The court found that both the initial adjudicating officer and the appellate tribunal had ignored PepsiCo's valid defense, leading to flawed orders in December 2018 and May 2024.
The High Court set aside both orders, fully exonerating PepsiCo India from the penalty. The ruling underscores the importance of substantive evidence in food safety cases and clarifies that marketing terms like 'Maha Value' are not inherently misleading.
