Bansal Milk Chilling Centre v. Rana Milk Food Private Ltd. (2025 SCC OnLine SC 1509) - The Supreme Court emphasized the importance of properly impleading the company when the act pertains to a corporate entity, ruling that officers cannot be prosecuted in isolation UDAYAKUMARI KS vs THIRUVANANTHAPURAM REPRESENTATIVES AND SALESMAN COOPERATIVE SOCIETY LTD (REPSCO) - Kerala, Champion Agro Ltd. vs Kotak Mahindra Bank Ltd. - Gujarat, Ashok Muthana vs UMS Technologies Pvt. Ltd. - Madras.
Amendment of Complaints - The Court reaffirmed that amendments to private complaints are permissible even after initial filing, especially at pre-cognizance stages, provided factual scenarios remain unchanged and no defense has been entered by the accused Champion Agro Ltd. vs Kotak Mahindra Bank Ltd. - Gujarat, MADHU vs VIBITHA - Kerala.
Legal Proceedings Related to Milk and Milk Products - Several cases involve cooperative societies, milk chilling centers, and related infrastructure, highlighting issues of ownership, rates, taxes, and operational costs associated with milk chilling centers B. Narasimha Reddy VS State of A. P. , rep. by its Secretary to Govt. of A. P. - Andhra Pradesh, A. P. Dairy Development Corporation Federation VS B. Narasimha Reddy - Supreme Court, Government Milk Scheme VS Assistant Commissioner of Income-tax, TDS Cir. 1/2 - Income Tax Appellate Tribunal.
Specific Case Details - In a notable case, the appellant mistakenly referred to Desi Ghee instead of milk in legal notices and complaints, but the courts have upheld amendments and clarified that such typographical errors do not bar legal proceedings Bansal Milk Chilling Centre VS Rana Milk Food Private Ltd. - Supreme Court, Ashok Muthana vs UMS Technologies Pvt. Ltd. - Madras.
Analysis and Conclusion:
The legal framework governing milk chilling centers involves complex issues of corporate liability, procedural amendments, and operational regulations. The Supreme Court’s rulings in Bansal Milk Chilling Centre v. Rana Milk Food Pvt. Ltd. underscore that amendments to complaints are allowed at early stages, and proper impleading of companies is essential when the act involves corporate entities. The cases also reflect ongoing legal considerations regarding the ownership, management, and regulatory compliance of milk chilling centers, emphasizing the importance of procedural accuracy and adherence to statutory requirements in the dairy industry.
Code, 1973 - Sections 200 and 482 - Amendment to complaint - The appellant alleged dishonor of cheques issued by respondents for milk ... 19-19) ... ... Facts of the case: ... The appellant filed a complaint for dishonor of cheques related to milk ... According to the complainant, while what was supplied was “milk”, by an inadvertent error “Desi Ghee (milk products)” was mentioned. The error which occurred in the legal notice was carried in the complaint also. ... The appellant contended that due to a typographical m....
In Bansal Milk Chilling Centre v. Rana Milk Food Private Ltd.
In support, reliance was placed on Bansal Milk Chilling Centre v. Rana Milk Food Pvt. Ltd. (2025 SCC OnLine SC 1509), S.R. Kumar v. S. Sunaad Raghuram (2015) 9 SCC 609, and UP Pollution Control Board v. ... Similarly, the judgments in Bansal Milk (supra) and S.R. Kumar (supra) do not dilute the mandatory requirement of impleading the company- when the act alleged is by the Company, its officers cannot be prosecuted in isolation.
The seminal issue pertaining to the permissibility of amendment in a private complaint, even at the stage of its maintainability, recently engaged the attention of the Apex Court in Bansal Milk Chilling Centre (supra). ... Reliance has been placed upon the judgment of the Hon’ble Supreme Court in Bansal Milk Chilling Centre v. Rana Milk Food Private Ltd. & Another, 2025 INSC 899, wherein it has been held that even at the post-cogniz....
The above preposition has also been followed by the Supreme Court in a subsequent decision in Bansal Milk Chilling Centre Vs. Rana Milk Food Private Limited and another [2025 SCC Online SC 1509]. ... According to the complainant, while what was supplied was “milk”, by an inadvertent error “Desi Ghee (milk products)” was mentioned. The error which occurred in the legal notice was carried in the complaint also. 18.
Recently, in Bansal Milk Chilling Centre v. Rana Milk Food Pvt. Ltd. [2025 KHC OnLine 6640], the Hon'ble Supreme Court has reiterated the above-stated principles to permit the amendment of a complaint. 11.
Learned advocate Mr.Ankit Shah for the petitioner relying on judgment of Hon’ble Apex Court in the case of Bansal Milk Chilling Centre v/s. ... Rana Milk Food Private Ltd. [2025 INSC 899] would submit that in complaint under section 138 of Negotiable Instrument Act, amendment is permissible at pre cognizable stage as factual scenario is not much changed, nor accused entered into defence at this stage.
Chairmen of the District Milk Producers Co-operative Unions filed Writ Petition - District Milk Producers Mutually Aided Co-operative ... Foundation, a society registered under the Andhra Pradesh Societies Registration Act, filed Writ Petition - Women Mutually Aided Milk ... under 1995 Act with 101 member village dairy co-operative societies, filed Writ Petition - Writ Petition was filed by 435 Primary Milk ... No.49, dated 11-02-1987 and 4 chilling centers and 5 mini chilling centers ....
In Harbilas Rai Bansal v. ... The Government of Andhra Pradesh introduced an integrated milk project in the State with the assistance of the UNICEF, according to which, the rural surplus milk produced in the villages was transported to chilling centres and supplied to consumers of Hyderabad. ... The High Court failed to make distinction of dairy milk societies from other co-operative societies as the dairy milk societies are having with them substantial government int....
Likewise, rates and taxes, ownership of refrigerator and investment made in those milk centres was stated to be the property of the centre owners. However, the ld. ... He has also clarified that as per G.R. dated 27-12-2000, the word ‘commission’ includes the reimbursement charges of milk transport, container expenditure, milk chilling charges etc. ... He has also mentioned that the payment of 90 paise per litre was in respect of transport cost, container charges, managemen....
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