Sumit Agarwal & Ors vs . Food Safety on 18 July, 2023
...30. It is significant to mention that the
Hon'ble Supreme Court in Godawat Pan
Masala Products I.P. Ltd. (supra) has
already held that COTPA, 2003 is a special
Act intended to deal with Tobacco and
Tobacco products, while Prevention of Food
Adulteration Act, 1954, is a general Act. In
the same analogy, the FSSA, 2006 being a
general Act, would yield to the provisions of
the COTPA, 2003, which is a special Act. It
is settled law that when a general Act is
specifically passed, it is logical to presume
that Parliament has not repealed or modified
the former special Act, unless anything to the
contrary appears from the subsequent
general Act.