Ratio Decidendi
Food safety offences are strict liability. The presence of extraneous matter (a caterpillar in a tin of peas) constitutes an offence regardless of the manufacturer's care, subject to the statutory defences.
ข้อเท็จจริง
A consumer found a caterpillar in a tin of peas manufactured by Smedleys. The company was prosecuted despite having extensive quality control procedures.
สรุปคำพิพากษา
The House of Lords held that the offence was committed regardless of the company's care. However, the statutory defence was available where all reasonable precautions had been taken.
คำกล่าวสำคัญ
"The Act imposes strict liability for food safety offences, subject to the statutory defences."
— Lord Hailsham
การอ้างอิงภายหลัง
Applied
Applied in subsequent food contamination prosecutions.