R was tried for an offense under the Prevention of Food Adulteration Act for selling adulterated curry powder. R claimed he purchased the curry powder sealed from the appellants and sold it unchanged. The appellants' representative testified they manufactured and sold the curry powder to R's business. R was acquitted. Subsequently, the appellants were prosecuted for issuing a false warranty. The appellants argued the proceedings against them should be quashed as they should have been joined in the case against R. The High Court and lower courts disagreed, finding nothing in the Act requiring the appellants to be joined. The Supreme Court upheld this decision, finding Section 20A allows but does not mandate joining the manufacturer in such cases, and lack of joinder