The case of State of Haryana versus Brij Lal Mittal involves the prosecution of the respondents as directors of a manufacturing company under the Drugs and Cosmetics Act. The key issue pertains to the vicarious liability of a person for offences committed by a company. The court examined whether the respondents, being directors, were in-charge of and responsible for the conduct of the company's business at the relevant time, which is a prerequisite for establishing liability under the relevant statutory provisions (!) .

The court found that the prosecution was initiated after the expiry of the shelf life of the drugs, which affected the respondents' right to have the drugs tested by the Central Drugs Laboratory, as provided under the relevant section of the Act. The High Court had quashed the proceedings on this basis, but the Supreme Court clarified that the expiration of the shelf life does not automatically invalidate the prosecution if other procedural requirements are met (!) (!) .

However, the court emphasized that the evidence on record did not sufficiently establish that the respondents were in-charge of and responsible for the company's conduct at the time of the offence. The mere assertion that they were directors was insufficient without concrete evidence demonstrating their role in the company's operations (!) (!) .

Furthermore, the court upheld the principle that vicarious liability requires proof of active responsibility and control over the company's conduct, which was lacking in this case. It also reinforced that individuals other than directors could be in-charge and responsible for the business, and such responsibility must be demonstrated with clear evidence (!) (!) .

In conclusion, the court dismissed the appeal, affirming the High Court's decision to quash the prosecution against the respondents due to the lack of sufficient evidence linking them to the conduct of the company's business at the relevant time (!) .