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Screen size of a mobile phone not ‘relevant’ under the Legal Metrology (Packaged Commodities) Rules, 2011
In Samsung India Electronics Private Limited vs. State of Andhra Pradesh[1], a single judge bench of the High Court of Andhra Pradesh (“AP HC”)[2] set aside the penalty proceedings initiated against Samsung India Electronics Private Limited (“Samsung”) for non-declaration of screen dimensions on mobile phone packaging. Samsung filed a writ petition under Article 226[3] of the Constitution of India challenging the order passed against it. The order held Samsung liable for violation of Sections 18 and 36[4] of the Legal Metrology Act, 2009 (“LM Act”) and Rules 4 and 6(1)(f) of the Legal Metrology (Packaged Commodities) Rules, 2011 (“LM Rules”). The AP HC held that the obligation to declare dimensions under Rule 6(1)(f) of the LM Rules is not absolute. It arises only where the size is ‘relevant’, i.e., where size is the metric by which the commodity is transacted in trade. A mobile phone’s screen cannot be treated as a separate commodity requiring an independent size declaration.
Brief facts
An Inspector of the Department of Legal Metrology seized 3 (three) packages of ‘Samsung Galaxy A31’ mobile phones, alleging that the packages did not contain a declaration of the screen size/dimensions, in violation of Sections 18 and 36 of the LM Act and Rules 4 and 6(1)(f) of the LM Rules.
Samsung made a representation for release of the seized packages. However, the Inspector passed an order holding that screen size is required to be declared and that Samsung had violated the applicable provisions. Samsung appealed under Section 50(1) of the LM Act before the controller of Legal Metrology, who dismissed the appeal on October 1, 2020.
Samsung’s principal contentions were that: (a) Rules 4 and 6(1)(f) of the LM Rules are not applicable to mobile phones as the price of a mobile phone depends on storage, processors, camera specifications, and other technical features rather than physical dimensions; (b) under Rule 15[5] of the LM Rules, dimensions need not be declared where they do not have a relationship to price; and (c) even assuming a violation, Sections 18 and 36 apply to misquotation of declarations, not non-disclosure.
The respondents contended that screen size influences every customer’s purchase decision, that the LM Rules do not discriminate between outer and inner form of the commodity, and that the screen is part of the dimensions of the mobile phone.
Issues
The AP HC framed the following issues for determination:
- whether the impugned order of Respondent 2 suffers from any illegality; and
- whether non-mentioning of the size of commodity (dimensions of the screen of the mobile phone) amounts to violation of Sections 18 and 36 of the LM Act and Rules 4 and 6(1)(f) of the LM Rules?
Findings and analysis
Section 18 of the LM Act mandates only ‘prescribed’ declarations on pre-packaged commodities. Rule 4 of the LM Rules requires every pre-packed commodity leaving the manufacturer’s premises to bear such prescribed declarations. Rule 6(1)(f) requires declaration of dimensions only “where the sizes of the commodity contained in the package are relevant”. The AP HC emphasised that this is a conditional obligation and not absolute.
Rule 15 of the LM Rules reinforces this position by requiring declaration of dimensions only “where the dimensions and weight, or combination thereof, of a commodity has or have a relationship to the price of that commodity”. Read together, Rules 6(1)(f) and 15 of the LM Rules present and obligation to declare size only where size is the metric by reference to which the commodity is transacted in trade.
The AP HC then examined Rule 14, which lists commodities where dimensions must be declared, for example, bed-sheets, hemmed fabric materials, dhoties, sarees, napkins, pillow-covers, towels, table cloths, or ‘similar other commodities’. The AP HC noted that all items listed in Rule 14 are articles whose utility, value, and manner of sale are closely tied to their physical dimensions.
Applying the ejusdem generis principle, the Court relied on the Constitution Bench decision in Amar Chandra Chakraborty vs. Collector of Excise, Government of Tripura[6], which laid down 5 (five) conditions for the doctrine to apply i.e., (a) the statute contains an enumeration of specific words; (b) the subjects of the enumeration constitute a class or category; (c) the class is not exhausted by the enumeration; (d) a general term follows the enumeration; and (e) there is no indication of a different legislative intent.
The AP HC held that the items in Rule 14 form a species articles sold by measurement and the residual phrase ‘similar other commodities’ must be confined to articles sharing that characteristic. It cannot be stretched to cover commodities whose value bears no relationship to physical measurement.
Three-part test for ‘relevance’ of size
The AP HC formulated a 3 (three)-part test for determining whether size is ‘relevant’ under Rule 6(1)(f) of the LM Rules:
- the commodity is, by trade practice, transacted or identified by reference to its physical dimensions;
- the dimensions bear a direct and proximate relationship to price, as contemplated by Rule 15 of the LM Rules; and
- an ordinary prudent purchaser would buy principally, not merely incidentally, on that basis.
The AP HC held that if any one of these conditions is absent, Rule 6(1)(f) of the LM Rules is not attracted, and no penal consequences can follow.
Applying this test to mobile phones, the AP HC observed that an ordinary prudent purchaser looks at brand, model number, storage capacity, Random Access Memory (“RAM”), International Mobile Equipment Identity (“IMEI”), maximum retail price, and manufacturer’s details. Physical dimensions are not the basis of identification, sale, or valuation of a mobile phone. The screen cannot be treated as a separate commodity as it is a component of the mobile phone, which is the pre-packaged commodity under the LM Rules.
The AP HC further held that Section 18 obligates only ‘prescribed’ declarations, and that the LM Rules, being delegated legislation under Section 52[7] of the LM Act, cannot travel beyond the parent statute. If the Respondent’s construction were accepted, every specification of every manufactured article would become a mandatory declaration which a result clearly not intended by the legislature.
Finally, the Court applied the principle of strict construction of penal provisions, relying on Tolaram Relumal vs. State of Bombay[8] and Balaji Traders vs. State of Uttar Pradesh[9]: where 2 (two) constructions of a penal provision are reasonably possible, the one that exempts the subject from penalty must be preferred.
Conclusion
This judgment provides clarity on the conditional nature of Rule 6(1)(f) of the LM Rules and limits the scope of mandatory size declarations to commodities that are, by trade practice, transacted by reference to their physical dimensions. The decision is particularly relevant for manufacturers and brand owners of electronic goods, technology products, and other commodities whose value is determined by functional specifications rather than physical measurements.
The 3 (three)-part test formulated by the AP HC for assessing ‘relevance’ of size under Rule 6(1)(f) provides a framework for manufacturers evaluating compliance obligations under the LM Rules. The application of ejusdem generis to Rule 14 narrows the category of ‘similar other commodities’ and offers a principled basis for excluding technology products from the dimensional declaration requirement.
Manufacturers and brand owners should note that this is a single-judge decision of the AP HC and may be subject to further challenge. However, it offers value on the interpretation of Rules 6(1)(f), 14, and 15 of the LM Rules, particularly in proceedings before Legal Metrology officers and appellate authorities across India.
This Prism has been prepared by:
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Probir Roy Chowdhury |
Nikhil George |
Aryaman Kumar |
For more details, please contact km@jsalaw.com.
[1] 2026 SCC OnLine AP 2709 (decided on July 22, 2026)
[2]Writ Petition No. 19262/2020
[3] Samsung invoked Article 226 of the Constitution of India before the AP HC seeking a writ of mandamus to set aside the orders of the Controller and the Inspector holding Samsung liable under the LM Act and the LM Rules for non-declaration of screen dimensions on mobile phone packaging.
[4] Samsung was proceeded against under Section 36 of the LM Act, which penalises the sale or possession for sale of pre-packaged commodities that do not conform to the declarations required under the LM Act, on the ground that the Samsung Galaxy A31 packaging did not declare screen size.
[5] Samsung relied on Rule 15 of the LM Rules, which requires declaration of dimensions only where they bear a relationship to the price of the commodity, to contend that mobile phone pricing depends on technical specifications, not physical dimensions.
[6] (1972) 2 SCC 442
[7] Samsung appealed under Section 50(1) of the LM Act before the Controller of Legal Metrology, who dismissed the appeal on October 1, 2020, confirming the Inspector’s order, prompting the writ petition before.
[8] (1954) 1 SCC 961
[9] (2025) 10 SCC 638
