Manoj vs. State of Maharashtra & Anr. (2026)

Supreme Court quashes conviction under Essential Commodities Act due to absence of subsisting statutory control order
Supreme Court of India


Legal Provisions Involved: Section 3 and Section 7 of the Essential Commodities Act, 1955; Maharashtra Cement (Licensing and Control) Order, 1973; Cement Control Order, 1967

Judgement by: Supreme Court of India

Judge/Bench: Justice B.V. Nagarathna and Justice R. Mahadevan

Facts

The Appellants were convicted for offences under the Essential Commodities Act, 1955. It was alleged that on 24.03.1994, Government quota cement meant for a PWD construction project was diverted and found stored in premises connected with the Appellants. The High Court affirmed the conviction, leading to the present appeal. 

Key Legal Provisions

Section 3 and Section 7 of the Essential Commodities Act, 1955; Maharashtra Cement (Licensing and Control) Order, 1973; Cement Control Order, 1967

Issues raised

  1. Whether the Cement Control Order, 1967 and Maharashtra State licensing regime remained operative on the date of the alleged offence.
  2. Whether a conviction under Section 7 of the Essential Commodities Act, 1955 can be sustained in the absence of a subsisting statutory order under Section 

Arguments of the case

The Appellants argued that no operative order existed on the date of the incident while the Respondents argued that the appellants possessed Government cement without valid licence, thereby contravening statutory provisions. It was further argued that the burden was upon the Appellants to explain lawful possession. 

Judgement

The Supreme Court allowed the appeals and set aside the conviction. The Court held that since statutory control over cement had been rescinded prior to the alleged offence, no subsisting order existed, making the prosecution legally untenable.

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