Background Matrix
In the Matter Samsung India Electronics Pvt. Ltd. v. State of Karnataka the petition filed by Samsung India seeking to stop legal action taken against the company for violating the Legal Metrology Act of 2009, the Legal Metrology Numeration Rules of 2011, the Legal Metrology Packaged Commodities Rules of 2011, and other rules. Samsung India is a well-known manufacturer, importer, marketer, and seller of consumer and household electronics and appliances through its distributors and retailers. A distributor for Samsung India, M/s. ABM Tele Mobiles India Pvt. Ltd., was examined by an inspector from the Department of Legal Metrology in Bengaluru. While evaluating a pre-packed Samsung Galaxy Tab-4 produced by Samsung, it was discovered that the MRP printed was Rs. 14,000, which was out of compliance with Sections 6(2) and (3) of the Legal Metrology Act, 2009, Rule 4(2) of the Legal Metrology Numeration Rules, 2011, and Rule 4(2) of the Legal Metrology Numeration Rules, 2011. The Inspector also claimed that the 2009 Metrology Act’s Sections 11 and 29 had been broken. In addition, the Inspector claimed to have examined a pre-packaged wholesale product with 20 individual packets that lacked the qualifying symbol “N” for quantity indication as required by Rule 13 (5)(ii) of the Legal Metrology (Packaged Commodities) Rules, 2011. It was asserted that the 2011 Packaged Commodities Rules were violated by just specifying the number “20” without the necessary qualifying unit “N.”
Contention from parties
Samsung India contended that The Numeration Rules, 2011, are only applicable for weight, measure, or number as specified in Section 52(2)(f) of the Metrology Act, 2009, and are thus not at all applicable for price/MRP of packaged goods, according to a combined reading of Sections 52 and 10 of the Metrology Act, 2009. The attorney also emphasised that MRP on pre-packaged items should follow Rule 2(m) of the 2011 Packaged Commodities Rules and not the 2011 Numeracy Rules. It was further emphasised that the product in question complies with legal requirements; as a result, the Inspector erred in his interpretation of the laws and regulations and arbitrarily issued a notice for compounding the alleged breaches without according to the rules of natural justice.
The defendant refused the aforementioned claims by claiming that Samsung India had ample chance to explain why the violations were compounded. The Inspector was forced to file a complaint since they did not provide a sufficient response.
Conclusion of the court
According to the Karnataka High Court’s single bench of Justice Sachin Shankar Magadum, the offences listed by the Inspector of the Department of Legal Metrology apply to retail packages only, not wholesale packages. As a result, the court found that, upon careful consideration of the allegations, it was obvious that the complaint was false. The court further ruled that the terms of the 2009 Act and the 2011 Packaged Commodities Rules had been gravely misunderstood in the contested case.
The Court emphasised that it is obvious from a cursory reading of Rule 2(m) that the Inspector misapplied the legislation that governs price and issued notice for compounding the alleged offence arbitrarily. Therefore, the Court was adamant that the contested complaint did not disclose any crimes and that it only indicated crimes that applied to retail packages rather than wholesale ones. The Court determined that the complaints’ claims were completely baseless and vexatious. The complaint itself is contradictory, according to the Court, and the relevant sections of the Metrology Act of 2009, Rule 2(m), and Rule 24(c), of the Packaged Commodities Rules of 2011, are all misinterpreted.