Case: Dharmendra Hansraj Kotak & Ors. v. State of Delhi & Anr.¹
Court: Delhi High Court
Decision: 6 August 2026
The Delhi High Court has quashed criminal proceedings arising from the 2015 Maggi controversy against Nestlé India Limited and other accused, holding that continuing the prosecution would amount to an abuse of the process of law.
The proceedings originated from samples of Maggi noodles collected in Delhi in 2015. Food Analyst reports had alleged that the lead content in the tastemaker exceeded the permissible limit, forming the principal basis of the criminal complaints.
However, the findings subsequently came under judicial scrutiny. Pursuant to proceedings before the Bombay High Court and Supreme Court, fresh testing was conducted through the CSIR-CFTRI, Mysore, a recognised referral laboratory. The subsequent testing materially affected the evidentiary basis of the original allegations.
The Delhi High Court observed that the prosecution substantially relied upon the original analytical reports and that, in light of the subsequent judicially supervised testing and the circumstances of the case, there was no useful purpose in allowing the criminal proceedings to continue.
Relying on the principles governing the High Court’s inherent jurisdiction, including those recognised in State of Haryana v. Bhajan Lal (1992)2 and Rajiv Thapar v. Madan Lal Kapoor (2013)³, the Court concluded that continuation of the proceedings would constitute an abuse of process.
Why It Matters
The ruling highlights a significant principle of criminal jurisprudence: a prosecution cannot be sustained indefinitely when its foundational evidence has been materially undermined.
It also underscores the importance of statutory compliance in sampling, laboratory testing and regulatory enforcement, particularly where regulatory findings form the basis of criminal prosecution.
Legal Takeaway: Regulatory action must rest on legally valid procedures and reliable scientific evidence. Where the evidentiary foundation of a criminal case no longer survives, the High Court can intervene to secure the ends of justice and prevent abuse of process.