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Issues:
1. Jurisdiction of the Court at Dhanbad 2. Whether the complaint was barred by limitation Analysis: The judgment pertains to a case involving the failure of the respondents, who are owners of a stone quarry, to furnish annual returns for the year 1959 to the Chief Inspector within the prescribed time. The issue of jurisdiction of the Court at Dhanbad and the bar of limitation for the complaint were raised in the Trial Court, High Court, and before the Supreme Court. The primary focus was on whether the offence constituted a continuing offence or a one-time offence under Sec. 66 of the Mines Act, 1952, and Sec. 79 regarding the limitation period for filing complaints. The Court deliberated on the distinction between a continuing offence and an offence committed once and for all. A continuing offence is one that persists until the rule or requirement is complied with, resulting in a fresh offence each time non-compliance occurs. Various illustrative cases were cited to elucidate this concept, emphasizing that the offence continues as long as the violation persists. The judgment highlighted that the offence in question must exhibit the element of continuance to fall under the Explanation of Sec. 79, thereby avoiding the bar of limitation. The Court cited examples from legal precedents to illustrate the nature of continuing offences, such as withholding money from a trade union, contravention of factory safety regulations, and unauthorized construction. These cases emphasized that the offence persists as long as the violation continues, triggering a new offence with each instance of non-compliance. The judgment underscored that the failure to furnish annual returns by the prescribed date does not constitute a continuing offence unless explicitly stated in the law. Ultimately, the Supreme Court upheld the High Court's decision that the complaint was time-barred as the offence in question fell within the substantive part of Sec. 79 of the Mines Act, rather than being covered by the Explanation. The Court concluded that the failure to furnish annual returns by the specified date did not amount to a continuing offence, leading to the dismissal of the appeals. The judgment reaffirmed the importance of distinguishing between offences committed once and for all and those that persist until compliance is achieved to determine the applicability of the limitation period for filing complaints.
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