This article critically examines the Supreme Court's decision in Sangam Milk Producer Company Ltd. V. Agricultural Market Committee, 2024 LiveLaw (SC) 204 : AIR 2024 SC 1423, a seminal case concerning the legal status of "ghee" under the Andhra Pradesh Agricultural Produce and Livestock Markets Act, 1966 (hereinafter referred to as the Act). The court held that the inclusion of ghee as a product of livestock for the purposes of levying market fees is justifiable under the Act, notwithstanding the argument that ghee is not directly extracted from livestock.

This ruling underscores the court's broad interpretation of statutory language, classifying ghee as a "product of a product of livestock". This article further analyses the nuanced distinctions between notifications issued under Sections 3 and 4 of the Act, the concept of unjust enrichment, and the Market Committee's powers under Section 4(3). We also contextualize the ruling with relevant legal doctrines, principles of statutory interpretation, and applicable case law.

Introduction
The term res inter alios acta—acts done between others—captures the essence of third-party objections often raised in administrative law. In Sangam Milk Producer Company Ltd. V. Agricultural Market Committee, the Supreme Court was tasked with interpreting a statutory regime that governs livestock products, specifically in relation to the inclusion of ghee as a product for the purpose of market fees. The appellants in this case contended that ghee, being a processed product derived from milk, does not constitute a livestock product under the ambit of the Act. However, the court, through a lens of purposive interpretation, concluded that ghee remains a product of livestock as it derives from milk, which is unquestionably a product of livestock.

This case not only addresses the classification of livestock products but also delves into the procedural distinctions between notifications issued under Sections 3 and 4 of the Act. These sections govern the notification process concerning agricultural produce, livestock, and their products, laying down the legal framework for the imposition of market fees.

1. Understanding the Statutory Framework: Agricultural Produce and Livestock Markets Act, 1966: The Andhra Pradesh Agricultural Produce and Livestock Markets Act, 1966 was enacted with the objective of regulating the purchase and sale of agricultural produce and livestock products within notified market areas. The Act ensures that agricultural markets function efficiently while protecting the interests of both producers and consumers. Under the Act, Market Committees are vested with the authority to levy market fees on the sale and purchase of agricultural produce and livestock products, ensuring that such transactions occur in a regulated manner.
    
2. The Legal Conundrum: Ghee as a Livestock Product: At the crux of Sangam Milk Producer Co. Ltd. V. Agricultural Market Committee lies the question of whether ghee qualifies as a livestock product. Ghee, a clarified form of butter, is derived from milk through a process of separation. The appellants contended that ghee, being a secondary processed product, could not be classified as a livestock product for the purposes of levying market fees under the Act. However, the Supreme Court rejected this contention, asserting that the statutory language must be interpreted expansively. The court reasoned that just because ghee is not directly obtained from livestock, it does not lose its character as a product of livestock. Milk, undeniably a product of livestock, undergoes transformation into butter, which is then further clarified into ghee. Thus, for all intents and purposes, ghee remains a product of livestock within the meaning of the Act. The court observed in Para 10:

   "The inclusion of ghee as a livestock product cannot be faulted merely because it is not directly obtained from milk. It remains a product of livestock for the purposes of the Act and payment of market fee."

   This interpretation aligns with the principle of verba legis, where the words of a statute are interpreted in their ordinary sense unless they lead to absurdity. The court's ruling reinforces a purposive approach to statutory interpretation, ensuring that the intent of the legislature is not defeated by a narrow construction of the words.
    
3. Sections 3 & 4 of the Act: Procedural Distinctions and Their Implications: The Supreme Court also addressed the procedural argument regarding the validity of the notification issued under Section 4 of the Act. The appellants argued that the notification should have adhered to the procedure prescribed under Section 3, which mandates a draft notification and the hearing of objections. However, the court clarified the distinction between notifications under Sections 3 and 4. Section 3 of the Act empowers the government to notify an area where the purchase and sale of agricultural produce, livestock, and livestock products may be regulated. This is a one-time measure that involves a detailed process, including the issuance of a draft notification and the consideration of objections. In contrast, Section 4 allows the government to declare a notified market area in respect of any product that has already been notified under Section 3. Importantly, Section 4 does not require the issuance of a draft notification or the hearing of objections. The court, in Para 11, explained:

   "The notification in question is a notification under Section 4, hence no prior process was required as contemplated under Section 3 of the Act for working the scheme under Section 4 of the Act. Hence, the challenge to the notification has rightly been turned down."

   This ruling emphasizes the principle of expressio unius est exclusio alterius—the express mention of one thing excludes others—by holding that the procedural safeguards of Section 3 cannot be read into Section 4 in the absence of explicit statutory language.
    
4. Unjust Enrichment and Liability to Pay Market Fees: The concept of unjust enrichment also emerged as a critical issue in this case. Section 4(3) of the Act empowers Market Committees to establish markets and provide necessary facilities within notified market areas. These facilities are availed by traders for the purchase and sale of notified products. In this case, the appellants had benefitted from the market facilities provided by the Market Committee, yet sought to evade the payment of market fees. The court, in Para 13, held:

   "The appellants have availed the facility given by the Market Committee and hence they are liable to pay the fee."

   The doctrine of quantum meruit—where a party should be compensated for the value of services provided—applies here. The appellants, having availed themselves of the benefits provided by the Market Committee, were deemed liable to pay the requisite market fees. This reinforces the legal principle that no party should unjustly enrich itself at the expense of another.
    
5. Case Law Analysis: The decision in Sangam Milk Producer Co. Ltd. finds resonance with previous rulings of the Supreme Court that have adopted a broad interpretation of statutory provisions concerning market regulation. For instance, in Agricultural Market Committee v. Shalimar Chemical Works Ltd., (1997) 5 SCC 516, the Court upheld the validity of market fees levied on processed agricultural products, reaffirming that the legislative intent of market regulation extends to products derived from agricultural produce. Similarly, in Bharat Krishak Samaj v. Union of India, AIR 1987 SC 1420, the Supreme Court emphasized the importance of market regulations to ensure fair and equitable trade practices. These cases, when read together with the present ruling, underscore the judiciary's commitment to upholding the objectives of market regulation laws.

Conclusion
In conclusion, the Supreme Court's ruling in Sangam Milk Producer Co. Ltd. V. Agricultural Market Committee reflects a purposive interpretation of the Andhra Pradesh Agricultural Produce and Livestock Markets Act, 1966. The court's expansive interpretation of the term "product of livestock" to include ghee underscores the principle that statutory provisions must be construed in light of their legislative intent. Furthermore, the procedural distinctions between notifications under Sections 3 and 4 of the Act highlight the importance of adhering to the specific requirements laid down by the legislature.

This decision reaffirms the importance of market regulation laws in ensuring a fair and equitable system of trade in agricultural produce and livestock products. The court's emphasis on the principles of unjust enrichment and the equitable distribution of market fees serves as a reminder that statutory obligations cannot be evaded under the guise of technicalities.

References:

• Sangam Milk Producer Company Ltd. V. Agricultural Market Committee, 2024 LiveLaw (SC) 204 : AIR 2024 SC 1423.
• Agricultural Market Committee v. Shalimar Chemical Works Ltd., (1997) 5 SCC 516.
• Bharat Krishak Samaj v. Union of India, AIR 1987 SC 1420.
• Andhra Pradesh Agricultural Produce and Livestock Markets Act, 1966.