Uttarakhand High Court Quashes Criminal Case Against Patanjali for Alleged Misleading Ads

In a strongly reasoned judgment dated June 3, 2025, the Uttarakhand High Court quashed criminal proceedings initiated against Patanjali Ayurved Ltd., its founders Baba Ramdev, Acharya Balkrishna, and others. The case, based on alleged misleading advertisements of Ayurvedic products, was dismissed due to procedural and legal infirmities.

Case Background

The State of Uttarakhand had filed Complaint Case No. 3892 of 2024 under Sections 3, 4, and 7 of the Drugs and Magic Remedies (Objectionable Advertisements) Act, 1954, alleging that Patanjali disseminated misleading advertisements for products like Madhugrit, Madhunashini, Swasari Gold, Drishti Eye Drops, and others. Summons were issued by the Chief Judicial Magistrate, Haridwar, on April 16, 2024.

Patanjali challenged the complaint under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), seeking to quash the summoning order and proceedings.

Key Grounds for Quashing

The High Court accepted several crucial arguments raised by Patanjali's counsel:

1. Limitation Bar:

Most alleged offences occurred before April 2023. As the maximum punishment under the 1954 Act is six months to one year, the Court held that Section 468 CrPC (now mirrored in BNSS) bars taking cognizance after one year—making the April 2024 summoning order legally time-barred.

2. Lack of Specific Allegations:

The complaint did not specify what was false or misleading in the advertisements, nor did it link the content to any disease listed in the Act's Schedule, which is a statutory requirement under Sections 3 and 4 of the 1954 Act.

3. No Proper Authorization:

The complaint was filed by a Senior Food Safety Officer, whereas the law mandates that only a properly authorized officer under Section 8 of the 1954 Act can file such complaints. This procedural error invalidated the proceedings.

4. No Evidence or Expert Opinion:

There was no expert opinion, no digital evidence certified under Section 65B of the Evidence Act, and no indication of how the advertisements were actually misleading.

5. No Judicial Application of Mind:

The Magistrate’s summoning and cognizance orders were non-speaking, lacked analysis of evidence, and appeared to have been passed in a mechanical manner without judicial reasoning.

Court’s Finding

Justice Vivek Bharti Sharma observed that:

"In the absence of allegation of falsity and the absence of the averment of the manner having tendency to mislead, no offence is made out... A person ought not to be dragged into court merely because a complaint has been filed."

Accordingly, the Court set aside the summoning order and quashed the proceedings.

Legal Significance

This judgment is an important reaffirmation of:

Strict procedural compliance in criminal complaints under special legislation like the 1954 Act.

The necessity of specific allegations and proper application of judicial mind before summoning accused persons.

Protection of individual and corporate reputations from vague or time-barred prosecutions.