# M/s Shree Shanker Medicals v. State of U.P. & Ors

- **Citation:** (2025) 2 ILRA 528
- **Court:** High Court of Judicature at Allahabad
- **Decided:** 2025-02-19
- **Case number:** Writ C No. 10598 of 2024
- **Bench:** Pankaj Bhatia
- **Source:** https://unisonlegal.in/judgment/allahabad-high-court/m-s-shree-shanker-medicals-v-state-of-u-p-ors-54546
- **Pages:** 8

## Headnote

A. Civil Law -Constitution of India,1950Article 226, 14 &19(1)(g)-Drugs and
Cosmetics
Act,1940-Section
23
-
Rules,1945-Cancellation of Drug LicenceImproper Sampling -Show cause notice
Deficiency-The petitioner challenged the
cancellation of its retail drug licence and
the dismissal of its statutory appeal-The
court held that the sampling process
violated the mandatory provisions of
section 23 of the Act,1940 as only one
sample was drawn instead of required
three or four-the second show cause
notice failed to propose cancellation or
allege
that
the
petitioner
was
the
manufacturer of the substandard drug-the
final order, presumed illegal manufacture
by the petitioner without supporting
evidence
or
confrontation
with
contradictory distributor replies-the court
held that this violated the petitioner's
rights under Article 14 and 19(1)(g) of the
Constitution and was a clear breach of
Rule 66 of the ,Rules 1945-consequently,
both the cancellation and appellate orders
were quashed and the petitioner's licence
was restored.(Para 1 to 21)

The writ petition is allowed. (E-6)
List of Cases cited:

UMC Techs. (P) Ltd. Vs FCI (2021) 2 SCC 551

## Text

528 INDIAN LAW REPORTS ALLAHABAD SERIES
Magistrate, Etah has cancelled the arms
licence of the petitioner on account of
misuse of weapon by threatening the
police. Although, in the order, reference
has been made to the criminal case pending
against
the
petitioner.
However,
the
cancellation of arms licence order itself
records that the petitioner has not been able
to show any acquittal order. It is admitted
to learned counsel for the petitioner that in
the criminal case charge sheet has been
submitted against the petitioner and charges
have been framed. The first information
report was in respect of the same incident,
which resulted in the cancellation of arms
licence.

9. It is further to be seen that the
findings recorded in the criminal case may
have an important bearing with regard to the
cancellation of arms licence of the petitioner
as the present proceedings are summary
proceedings. However, in the trial if the
petitioner is convicted, the same may fortify
the stand taken by the State for cancellation
of arms licence. However, the acquittal order
would also equally effects the cancellation of
the arms licence and that is why the
Licensing Authority has recorded a specific
finding that no acquittal order has been
produced by the petitioner.

10. In the present case, the defence of
the petitioner was to the extent that the
petitioner is running a hotel where the police
personnel have attended and consumed food
including liquor. However, the petitioner
objected for consumption of liquor in the
hotel. The money of the food was demanded
and the same was denied, which resulted in
the lodging of the first information report.

11. On a query being made to learned
counsel for the petitioner as to what was the
evidence lead in support of the defence of the
petitioner that the police personnel have
abused their authority and have not paid the
money for food, learned counsel for the
petitioner could not demonstrate from record
any material evidence. The defence of the
petitioner qua the cancellation of the arms
licence was required to be proved by the
petitioner by leading evidence. Since the
petitioner has not lead any evidence,
therefore, it cannot be said that the petitioner
has not misuse the firearm. It has also not
been demonstrated that the report of the
Senior Superintendent of Police, Etah dated
3.11.2016 is incorrect.

12. In view of the aforesaid, no error
has been shown by the learned counsel for
the petitioner in the impugned orders. The
writ
petition
lacks
merit
and
is,
accordingly, dismissed.

13. However, in the event, an acquittal
order is passed in favour of the petitioner in
the criminal trial, the petitioner would be at
liberty to apply before the Licensing
Authority for restoration of the arms
licence in accordance with law.
----------
(2025) 2 ILRA 528
ORIGINAL JURISDICTION
CIVIL SIDE
DATED: LUCKNOW 19.02.2025

BEFORE

THE HON'BLE PANKAJ BHATIA, J.

Writ C No. 10598 of 2024

M/s Shree Shanker Medicals ...Petitioner
Versus
State of U.P. & Ors. ...Respondents

Counsel for the Petitioner:
Ayodhya
Prasad
Mishra,
A.P.
Mishra,
Jaylaxmi Upadhyay, Rituraj Mishra, Shesh
Ram Verma
2 All. M/s Shree Shanker Medicals Vs. State of U.P. & Ors.
529
Counsel for the Respondents:
C.S.C.

A. Civil Law -Constitution of India,1950Article 226, 14 &19(1)(g)-Drugs and
Cosmetics
Act,1940-Section
23
-
Rules,1945-Cancellation of Drug LicenceImproper Sampling -Show cause notice
Deficiency-The petitioner challenged the
cancellation of its retail drug licence and
the dismissal of its statutory appeal-The
court held that the sampling process
violated the mandatory provisions of
section 23 of the Act,1940 as only one
sample was drawn instead of required
three or four-the second show cause
notice failed to propose cancellation or
allege
that
the
petitioner
was
the
manufacturer of the substandard drug-the
final order, presumed illegal manufacture
by the petitioner without supporting
evidence
or
confrontation
with
contradictory distributor replies-the court
held that this violated the petitioner's
rights under Article 14 and 19(1)(g) of the
Constitution and was a clear breach of
Rule 66 of the ,Rules 1945-consequently,
both the cancellation and appellate orders
were quashed and the petitioner's licence
was restored.(Para 1 to 21)

The writ petition is allowed. (E-6)
List of Cases cited:

UMC Techs. (P) Ltd. Vs FCI (2021) 2 SCC 551
(Delivered by Hon'ble Pankaj Bhatia, J.)

1. Heard learned counsel for the
petitioner and learned Standing Counsel for
the State-respondents.

2. The present petition has been filed
challenging an order dated 12.06.2023,
whereby the licence granted to the
petitioner for retail sale of the drugs under
the Drugs and Cosmetics Act, 1940
(hereinafter referred to as 'the Act) was
cancelled as well as the appellate order
dated 05.06.2024, whereby the appeal was
dismissed.
The
petitioner
has
also
challenged the show cause notice, which is
contained in Annexure No.1 to the writ
petition.

3. The facts, in brief, are that the
petitioner was running a retail shop for sale
of drugs and cosmetics after obtaining a
licence on 09.11.2004, which permitted the
retail sale of the medicines. The said
licence was renewed subsequently on 30th
October, 2019 and continued to be valid till
the year 2024. However, on 22.12.2022, an
inspection was carried out on the shop of
the petitioner on the basis of some
complaint made by one manufacturer of the
medicines, namely, Dr. Reddy. The Drug
Inspector, carried out an inspection and
noted certain irregularities, for which a
seizure memo was also prepared on the said
date, which is on record at page No.51 of
the paper book. In terms of the said seizure
memo, the name of the complainant was
also referred and the sample of six
medicines were recovered. In pursuance of
the said search carried out, a show cause
notice was issued on 03.01.2023 calling
upon
the
petitioner
to
explain
the
irregularities as noticed in the search. It is
claimed that on 17.01.2023, the petitioner
gave
a
reply
denying
the
alleged
irregularities. The said irregularities did not
pertain to the six medicines, which were
seized through the seizure memo. Despite
the reply being given by the petitioner to
the
first
show
cause
notice
dated
03.01.2023, an order came to be passed on
31.01.2023 suspending the drug licence of
the petitioner in terms of the power
conferred by virtue of the Rule 66 of the
Drugs
and
Cosmetics
Rules,
1945
(hereinafter referred to as "the Rules). It
appears from the record that on 06.02.2023,
a chemical examination report was issued
530 INDIAN LAW REPORTS ALLAHABAD SERIES
in respect of one out of six samples seized,
wherein it was noticed that the sample does
not confirm with a declared formula in
respect of contents of Omeprazole and
Demperidone. In pursuance of the said
report, which can be read at page No.59 of
the paper book, a show cause notice was
issued on 03.03.2023 to one M/s. Bhagat
Distributors, from whom, the petitioner had
claimed that the drug was purchased and
was kept for sale. The petitioner was served
with the second show cause notice on
31.03.2023, calling upon the petitioner to
do three things. The first to stop the
distribution of the said drug and to produce
the licence; second to disclose the name of
the manufacturer along with proof and also
do recall the drugs already sold in the
market; and the third being to disclose the
distribution manner of the said drug along
with the evidences and also to disclose as
to whom the said drug was sold along with
the bill vouchers etc. It was indicated in the
said notice that in the absence of giving the
reply as desired in respect of the three
aspects, a suitable action shall be taken
under the provisions of the Act. A copy
of the report was also furnished to the
petitioner. The petitioner once again gave a
reply to the said second show cause notice
on 11.04.2023 denying the allegations. He
also disclosed that he had purchased the
said medicines through invoices numbers
disclosed in the reply from the whole sale
distributor M/s. Bhagat Distributors. It
appears that on 20th April, 2023, the said
M/s. Bhagat Distributors also gave a reply
and disputed the sale of the drug to the
petitioner as claimed by the petitioner.
Thereafter, on 12.06.2023, an order came
to be passed cancelling the drug licence of
the petitioner. The said order is contained
in Annexure No.2 to the writ petition. The
petitioner, thereafter preferred an appeal
against the said order as prescribed. The
same was also dismissed by means of an
order dated 21.05.2024, which is on record
as Annexure No.3 to the writ petition and
also impugned in the present petition.

4. The submission of Shri Ayodhya
Prasad Mishra, learned counsel for the
petitioner is that the manner of sampling
was contrary to the mandatory provisions
contained in Section 23(4) of the Act He
argues that the three samples as are
prescribed under sub-section 4 of Section
23 were not drawn and only one sample
was drawn. He further relies upon the
provisions contained in Section 25 of the
Act to argue that if the samples were
wrongly drawn the petitioner is denied the
opportunity to challenge the finding as
conferred by Section 25(4) of the Act,
which is absent in the present case.

5. He further argues that in the second
show cause notice, which led to the passing
of the cancellation order, the cancellation
was not proposed and the petitioner was
only called upon to give reply in respect of
the three things as mentioned in the second
show cause notice and thus, the order of
cancellation is without any show cause
notice, which is mandatory in terms of Rule
66 of the Rules. He further argues that the
report/reply submitted by the M/s. Bhagat
Distributors was never provided to the
petitioner nor was he confronted with the
same, as such, it was a case of one reply
given by the petitioner and a contrary reply
given by the distributor, which ought to
have been verified before passing the order
impugned.

6. He further argues that the power of
cancellation of the licence as vested by
virtue of Rule 66 of the Rules is not to be
exercised in a mechanical manner as it
empowers the authority to cancel the
2 All. M/s Shree Shanker Medicals Vs. State of U.P. & Ors.
531
licence either wholly or in respect of some
of the substances. He also argues that the
power of cancellation has to be exercised
qua the conditions imposed in the licence,
whereas the order of cancellation has been
passed holding that the petitioner was the
manufacturer of the said drug without there
being any material in the form of evidence
either alleged or established to come to the
conclusion that the petitioner was a
manufacturer
and
thus,
the
orders
impugned are clear transgression of the
statutory prescriptions and are liable to be
quashed.

7. He argues that the right of the
petitioner to carry business in accordance
with the licence granted stands violated on
account of said two orders, which are also
violative of Article 19 of the Constitution
of India. Thus, both the orders suffer from
the vice of violating Article 19 and Article
14 of the Constitution of India and are
liable to be set aside.

8. Learned Standing Counsel on
behalf of the respondents argues that the
order has been passed based upon the
seizure of the drug at the time of
inspection by the Inspector of the drug,
who is well and duly empowered to carry
out the inspection and in the said
inspection, six drugs including the drug,
which was found short of standard were
seized and the same was sent for analysis.
In the analysis, the same were found to be
short of the quality. He argues that the
licensing authority has passed the order
after ascertaining the fact from the
distributor from which the petitioner
claimed to have purchased the medicines
and as he had denied having sold such
medicines, the only logical conclusion
was to cancel the licence, which has been
done
by
means
of
the
impugned
judgement, as such, the writ petition
deserves to be dismissed.

9. Before adverting to the factual
submissions as recorded above, it is
essential to see the mandate of the Drugs
and Cosmetics Act, 1940, which is
enacted in India to regulate the sale of
drugs and cosmetics. Chapter IV of the
said Act, essentially deals with the
regulation of manufacture and sale of
drugs and cosmetics in India. In terms of
the powers conferred by virtue of Section
6(2), 12, 33 and 33(N) of the Act, 1940,
the Central Government has framed rules
known as the Drugs and Cosmetics Rules,
1945.

10. For the present case, part VI of
the said Rules are the relevant rules,
which prescribed the manner of sale of
the drugs. The restrictions, which are
prescribed and the power to take action if
infractions are noticed.

11. Section 23, 24, 25 of the Act, 1940
and Rule 66 of the Rules, 1945, which are
relevant for the purpose of the present case,
are reproduced herein-below:-

"23. Procedure of Inspectors.-
(1) Where an Inspector takes any sample of
a drug or cosmetic under this Chapter, he
shall tender the fair price thereof and may
require a written acknowledgment therefor.

(2) Where the price tendered
under sub-section (1) is refused, or where
the Inspector seizes the stock of any drug
or cosmetic under clause (c) of section 22,
he shall tender a receipt therefor in the
prescribed form.

(3) Where an Inspector takes a
sample of a drug or cosmetic for the
purpose of test or analysis, he shall
intimate such purpose in writing in the
532 INDIAN LAW REPORTS ALLAHABAD SERIES
prescribed form to the person from whom
he takes it and, in the presence of such
person unless he wilfully absents himself,
shall divide the sample into four portions
and effectively seal and suitably mark the
same and permit such person to add his
own seal and mark to all or any of the
portions so sealed and marked:

Provided that where the sample is
taken from premises whereon the drug 3 or
cosmetic is being manufactured, it shall be
necessary to divide the sample into three
portions only:

Provided further that where the
drug or cosmetic is made up in containers
of small volume, instead of dividing a
sample as aforesaid, the Inspector may,
and if the drug 3 or cosmetic be such that it
is likely to deteriorate or be otherwise
damaged by exposure shall, take three or
four, as the case may be, of the said
containers after suitably marking the same
and, where necessary, sealing them.

(4) The Inspector shall restore
one portion of a sample so divided or one
container, as the case may be, to the person
from whom he takes it, and shall retain the
remainder and dispose of the same as
follows:?

(i) one portion or container he
shall forthwith send to the Government
Analyst for test or analysis;

(ii) the second he shall produce to
the Court before which proceedings, if any,
are instituted in respect of the drug or
cosmetic;

(iii) the third, where taken, he
shall send to the person, if any, whose
name, address and other particulars have
been disclosed under section 18A.

(5) Where an Inspector takes any
action under clause (c) of section 22,?

(a) he shall use all despatch in
ascertaining whether or not the drug 3 or
cosmetic contravenes any of the provisions
of the section 18 and, if it is ascertained
that the drug 3 [or cosmetic] does not so
contravene, forthwith revoke the order
passed under the said clause or, as the case
may be, take such action as may be
necessary for the return of the stock seized;

(b) if he seizes the stock of the
drug 3 [or cosmetic], he shall as soon as
may be inform a Judicial Magistrate and
take his orders as to the custody thereof;

(c) without prejudice to the
institution of any prosecution, if the alleged
contravention be such that the defect may
be remedied by the possessor of the drug or
cosmetic, he shall, on being satisfied that
the defect has been so remedied, forthwith
revoke his order under the said clause.

(6) Where an Inspector seizes any
record, register, document or any other
material object under clause (cc) of sub-
section (1) of section 22, he shall, as soon
as may be, inform a Judicial Magistrate
and take his orders as to the custody
thereof.

24. Persons bound to disclose
place where drugs or cosmetics are
manufactured or kept. -Every person for
the time being in charge of any premises
whereon any drug or cosmetic is being
manufactured or is kept for sale or
distribution shall, on being required by an
Inspector so to do, be legally bound to
disclose to the Inspector the place where
the drug or cosmetic is being manufactured
or is kept, as the case may be.

25.
Reports
of
Government
Analysts.-(1) The Government Analyst to
whom a sample of any drug or cosmetic
has been submitted for test or analysis
under sub-section (4) of section 23, shall
deliver to the Inspector submitting it a
signed report in triplicate in the prescribed
form.

(2) The Inspector on receipt
thereof shall deliver one copy of the report
2 All. M/s Shree Shanker Medicals Vs. State of U.P. & Ors.
533
to the person from whom the sample was
taken and another copy to the person, if
any, whose name, address and other
particulars have been disclosed under
section 18A, and shall retain the third copy
for use in any prosecution in respect of the
sample.

(3) Any document purporting to
be a report signed by a Government
Analyst under this Chapter shall be
evidence to the facts stated therein, and
such evidence shall be conclusive unless
the person from whom the sample was
taken or the person whose name, address
and other particulars have been disclosed
under section 18A has, within twenty-eight
days of the receipt of a copy of the report,
notified in writing the Inspector or the
Court before which any proceedings in
respect of the sample are pending that he
intends
to
adduce
evidence
in
controversion of the report.

(4) Unless the sample has already
been tested or analysed in the Central
Drugs Laboratory, where a person has
under sub-section (3) notified his intention
of adducing evidence in controversion of a
Government Analyst's report, the Court
may, of its own motion or in its discretion
at the request either of the complainant or
the accused, cause the sample of the drug
or cosmetic produced before the Magistrate
under subsection (4) of section 23 to be
sent for test or analysis to the said
Laboratory, which shall make the test or
analysis and report in writing signed by, or
under the authority of, the Director of the
Central Drugs Laboratory the result
thereof, and such report shall be conclusive
evidence of the facts stated therein.

(5) The cost of a test or analysis
made by the Central Drugs Laboratory
under sub-section (4) shall be paid by the
complainant or accused as the Court shall
direct.

Rule
66.
Cancellation
and
suspension of licences. (1) The Licensing
Authority may, after giving the licensee an
opportunity to show cause why such an
order should not be passed by an order in
writing stating the reasons therefor, cancel
a licence issued under this Part or suspend
it for such period as he thinks fit, either
wholly or in respect of some of the
substances to which it relates, if in his
opinion, the licensee has failed to comply
with any of the conditions of the licence or
with any provisions of the Act or Rules
thereunder:

Provided that, where such failure
or contravention is the consequence of an
act or omission on the part of an agent or
employee, the licence shall not be cancelled
or suspended if the licensee proves to the
satisfaction of the licensing authority?

(a) that the act or omission was
not instigated or connived at by him or, if
the licensee is a firm or company, by a
partner of the firm or a director of the
company, or

(b) that he or his agent or
employee had not been guilty of any similar
act or omission within twelve months
before the date on which the act or
omission in question took place, or where
his agent or employee had been guilty of
any such act or omission the licensee had
not or could not reasonably have had,
knowledge of that previous act or omission,
or

(c) if the act or omission was a
continuing act or omission, he had not or
could not reasonably have had knowledge
of that previous act or omission, or

(d) that he had used due diligence
to ensure that the conditions of the licence
or the provisions of the Act or the Rules
thereunder were observed.

(2) A licensee whose licence has
been suspended or cancelled may, within
534 INDIAN LAW REPORTS ALLAHABAD SERIES
three months of the date of order under
sub-rule (1), prefer an appeal against that
order to the State Government, which shall
decide the same."

12. In the present case the manner in
which the sample was drawn is clearly
contrary to the mandate of Section 23 of
the Act.

13. In the present case, it is also
evident from the facts as pleaded and
recorded above, an inspection was carried
out and a show cause notice was issued
regarding the irregularities, noticed on
03.01.2023, to which a reply was submitted
by the petitioner. However, after the report
was obtained with regard to the one of the
medicines, which are seized, the second
show
cause
notice
was
issued
on
310.03.2023 based upon the said chemical
examination report. In the said second
show cause notice, it was mentioned that
on the basis of analysis, the sample was
found not to be confirming to the declared
formula in respect of the said medicines
and the petitioner was called upon to follow
the three conditions, which are as under:-

"1. ववियािंकित औिधध िा अद्यतन
िण्डार बताये तर्ा उक्त औिधध िा ववतरर् न
िरे सार् ह अपने फमथ िा लाइसेंस प्रस्तुत
िरे।

2. ववियािंकित औिधध िा रय
वववरर् एव यनमाथता िा नाम पता प्रमार् िे
सार् प्रस्तुत िरे तर्ा ववतररत िी र्ई औिधध
िो वापस मिंर्ाये।

3. ववियािंकित औिधध िा ववतरर्
वववरर्, यनम्न सूचनाओिं िे सार् प्रस्तुत िरे
यर्ा वाऊचर सिंख्या, ददनाि औिधध िी मात्रा,
उस व्यजक्त/फमथ िा नाम पता जजसिो
ववियािंकित औिधध ववतररत िी र्यी हो।"

14. The petitioner was also called
upon to give a reply within a period of
three days, failing which, it was prescribed
that the action shall be taken in accordance
with law. In the entire show cause notice,
there was no mention that the petitioner
was responsible for manufacture of the
drugs nor was the petitioner called upon to
explain with regard to any steps that he
may have taken with regard to the
manufacture of the drugs. The reply was
duly submitted by the petitioner to the said
show
cause
notice
also.
The
order
impugned, however, proceeds to record that
there was a presumption that the petitioner
had manufactured the drugs, inasmuch as,
it has been recorded in the order that as per
the above, it was established that the
petitioner was manufacturing the drugs in
an illegal manner and was selling the same,
which was injurious to the health. The said
finding has been recorded, based upon no
evidence whatsoever. The show cause
notice was silent with regard to the
allegation
of
the
petitioner
having
manufactured any drugs. No evidence is
found either in the order or in the show
cause notice to suggest that the petitioner
was guilty of manufacture of the drugs.

15. It is very well settled that any
allegation especially of the nature which
are as serious as levelled in the present
case, have to be served with the show cause
notice. The contents of the show cause
notice should be clear and explicit in the
terms of the allegations. The show cause
notice cannot be vague and in the absence
of there being a clear allegation with regard
to the manufacture of the drugs, no finding
could have been recorded as have been
2 All. M/s Al-Haq Foods Pvt. Ltd. Vs. State of U.P. & Ors.
535
done by means of the cancellation order
dated 12.06.2023. It is well settled that a
show cause notice should specify particular
grounds on the basis of which action is
proposed to be taken as held by Supreme
Court in (2021) 2 SCC 551 UMC
Technologies
(P)
Ltd.
Vs.
Food
Corporation of India.

16. As regards, the sale of the said
drugs, there is no finding that the reply
given by the petitioner is correct or that of
M/s. Bhagat Distributors is correct. There
being no finding to that effect coupled with
the fact that the petitioner was never even
confronted with the reply submitted by the
distributor M/s. Bhagat Distributors. Even
the finding with regard to the sale of the
said medicines, is perverse.

17. It is essential to notice the mandate
of Section 19(3) of the Act, whereby the
person who is distributing the drugs
purchased from it a licensed distributor is
exempted even from prosecution by the
mandate of Section 19(3) of the said Act. In
the absence of any finding that the sale was
illegal at the instance of the distributor or at
the instance of the petitioner, the finding to
that effect cannot be sustained.

18. In the present case, where the
serious infraction of the Drug Inspector in
not following the mandate of Section 23,
24 and 25 of the Act, inasmuch as, the
manner of drawing the sample, which is
mandatory has not been followed. In the
absence of sampling being strictly in
accordance with the mandate of Section 23,
any infraction on that count cannot be
sustained.

19. For all the reasons recorded
herein-above, the two orders cannot be
sustained and are quashed.

20. The licence of the petitioner shall
be treated to be valid till 08.11.2024 and on
the petitioner moving an application for
renewal, the same shall be considered in
accordance with law.

21. The writ petition is allowed.
----------
(2025) 2 ILRA 535
ORIGINAL JURISDICTION
CIVIL SIDE
DATED: LUCKNOW 13.02.2025

BEFORE

THE HON'BLE ATTAU RAHMAN MASOODI, J.
THE HON'BLE SUBHASH VIDYARTHI, J.

Writ C No. 10671 of 2024

M/s Al-Haq Foods Pvt. Ltd. ....Petitioner
Versus
State of U.P. & Ors. ...Respondents

Counsel for the Petitioner:
Abhinav Singh, Lalta Prasad Misra

Counsel for the Respondents:
C.S.C., Ashok Kumar Verma

A. Environmental Law - Cancellation of
authorization - Slaughter house - Water
(Prevention and Control of Pollution) Act,
1974 - Air (Prevention and Control of
Pollution) Act, 1981.

The law does not compel a man to do
that
which
he
cannot
possibly
perform.
The
order
of
the
Hon'ble
Supreme Court to prepare an index of the
relevant laws for circulation to all the
concerned so that the management of
slaughtering the animals and slaughter
house should be done more efficiently,
can by no stretch of imagination be
interpreted
in
a
manner
that
the
requirements of all the 24 laws mentioned
in the compendium have to be fulfilled
before
establishment
of
a
slaughter
house. (Para 64, 66)