Andhra Pradesh High Court quashes case against Samsung over screen size labelling

Justice Subba Reddy Satti

Case

The dispute arose after officials inspected a retailer’s premises in Kadapa district in June 2020 and seized three Samsung Galaxy A31 mobile phone packages, alleging that they did not carry a declaration regarding the dimensions or size of the phones’ screens.

The authorities treated this as a violation of Sections 18 and 36 of the Legal Metrology Act, 2009 and Rules 4 and 6(1)(f) of the Legal Metrology (Packaged Commodities) Rules, 2011.

Samsung argued that Rules 4 and 6(1)(f) of the Legal Metrology (Packaged Commodities) Rules, 2011 were not applicable to the mobile phones seized by the authorities. Referring to Rule 15 of the Rules, Samsung submitted that there was no requirement to declare the dimensions of the phones on the packaging. It further argued that even if any non-disclosure were assumed, such an omission would not attract penalties under Sections 18 and 36 of the Legal Metrology Act, 2009. According to the company, these provisions apply in cases where a manufacturer makes an incorrect or misleading declaration, and not where a particular detail has merely not been disclosed.

While examining Rule 6(1)(f), the court observed that the requirement to declare dimensions is conditional and applies only where the size of a commodity is relevant. It held that the obligation is not an absolute statutory requirement for every packaged product.

The court noted that mobile phones are ordinarily identified and sold based on their brand, model, processor, memory, camera and other functional specifications, and not by reference to their physical dimensions. “Essentially every specification of a mobile phone may be said to influence purchase decisions and pricing, but that does not render each such specification a “relevant” detail required to be declared under Rule 6(1)(f),” the court observed.

To determine when dimensions become relevant, the court formulated a three-part test. It held that dimensions must be declared only where the commodity is ordinarily traded or identified by its physical dimensions, where dimensions have a direct relationship with price, and where an ordinary purchaser primarily buys the product on that basis.

The court observed that consumers generally purchase phones based on factors such as storage capacity, RAM, model number, MRP and manufacturer details, while physical dimensions are not the principal basis for identification, sale or valuation.

“Given the discussion supra, the invocation of Sections 18 and 36 of the Act read with Rules 4 and 6(1)(f) of the 2011 Rules against the Petitioner cannot be sustained. The orders impugned are liable to be set aside,” the court said.

The court, therefore, allowed the petition and set aside the proceedings against the company.