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Issues:
1. Petitions for quashing proceedings filed out of time. 2. Liability of individuals for alleged offences committed by a company. Analysis: Issue 1: The judgment involves 17 applications seeking to quash proceedings on the grounds of untimely petition of complaints. The first group of cases (Criminal Revision Nos. 2249 to 2262 of 1919) pertains to non-deposit of Provident Fund Amounts for specific months. The contention was that the complaints were filed beyond the limitation period as per Section 468(2)(b) of the Code. The court referred to a previous decision where it was held that complaints filed beyond one year are time-barred. The Union of India conceded to the limitation argument, leading to the success of these applications based on the limitation issue. Issue 2: The second group of cases (Criminal Revision Nos. 2263 to 2265 of 1979) involved allegations against a company for non-payment of Provident Fund amounts. The petitions of complaint were filed within the prescribed time. The argument presented was that only the company should be held liable for the alleged offences as per Section 14A(1)(2) of the Employees' Provident Fund and Miscellaneous Provisions Act, 1952. The petitioner, being a director, contended that individual liability should not apply unless they were directly involved in the day-to-day business operations. Citing legal precedents, it was established that directors should not be vicariously liable unless they were in control of the company's daily affairs. The court agreed with this argument and quashed the proceedings against the petitioner. In conclusion, the judgment quashed the proceedings in the mentioned cases based on the issues of untimely complaints and the incorrect attribution of individual liability for company-related offences.
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