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In V.Shantha v. State of Telangana and Others2 while considering the various provisions of the Act, the Apex Court held as under:

"The detenu was the owner of Laxmi Bhargavi Seeds, district distributor of Jeeva Aggri Genetic Seeds. Three FIRs were lodged against the detenu and others under Sections 420, 120-B, 34 IPC and Sections 19 and 21 of the Seeds Act, 1966. It was alleged that chilli seeds sold were spurious, as they did not yield sufficient crops, thus causing wrongful loss to the farmers, and illegal gains to the accused. Whether the seeds were genuine or not, the extent of the yield, are matters to be investigated in the FIRs. Section 19 of the Seeds Act provides for penalty by conviction and sentence also. Likewise, Section 20 provides for forfeiture. Sufficient remedies for the offence (2017) 4 SCC 577 ARR, J & GSD, J Wp_12466_2021 alleged were, therefore, available and had been invoked also under the ordinary laws of the land for the offence alleged.