Delhi High Court stays Regulatory Directions against Reliance’s Campa “Energy Drink”

Introduction

The Hon’ble Delhi High Court, vide its order dated 6 October 2026, has granted interim relief to Reliance Consumer Products Limited (“RCPL”) in proceedings concerning its product “Campa Energy Drink – Gold Boost” and the regulatory action taken by the Food Safety and Standards Authority of India (“FSSAI”). The Court stayed the regulatory directions requiring RCPL to remove the description “Energy Drink” from the product name, while clarifying that the interim relief does not permit further manufacture of the product using the disputed descriptor.

Background

By an order dated 30 June 2026, the Food Safety and Standards Authority of India (“FSSAI”), as the concerned food safety regulator, held RCPL’s product Campa Energy Drink – Gold Boost to be a case of misbranding and directed RCPL to remove the description “Energy Drink” from the product name. Pursuant to the said order, letters were also issued to State authorities for initiating enforcement action. RCPL challenged the regulatory action before the Delhi High Court, principally contending that the order dated 30 June 2026 had been passed without issuance of a Show Cause Notice (“SCN”) or providing an opportunity of hearing. The respondents submitted that RCPL had subsequently participated in certain meetings and had agreed to implementation of the impugned order.

Court’s Reasoning

While considering RCPL’s request for interim relief, the Court noted that:

• The impugned order was undisputedly passed without issuance of an SCN to RCPL.
• RCPL was not provided an opportunity of hearing before the order was passed.
• The impugned order would have a prejudicial effect on RCPL.
• In view of the above, the Court stayed the order dated 30 June 2026 as well as the consequential order dated 17 July 2026, until the next date of hearing.
• The respondents were directed to file their reply before the next date of hearing.

Scope of the Interim Relief

The Court specifically clarified that the stay shall not be interpreted as permitting RCPL’s bottlers/contractors to further manufacture the product using the term “Energy Drink.” Thus, the interim protection does not amount to a finding that RCPL is entitled to manufacture the product bearing the disputed descriptor pending adjudication of the matter.

Key Takeaway

The order reinforces the importance of procedural safeguards where regulatory action has prejudicial consequences for an affected party. While the Court has stayed the impugned regulatory directions on account of the absence of an SCN and opportunity of hearing, it has not adjudicated the substantive issue of whether “Energy Drink” is a permissible description for the product. The express restriction on further manufacture using the descriptor also makes clear that the interim relief is limited in scope. The matter is scheduled to be heard next on 5 November 2026.