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Validity of judgment and order of High Court of Rajasthan in a criminal case barred by limitation under Section 468 Cr. P.C. Analysis: The Supreme Court granted special leave to hear the case where the State of Rajasthan challenged the High Court's judgment quashing a criminal case based on the limitation period. The case involved collecting drug samples in 1988, finding them substandard, and filing a complaint in 1991. The High Court quashed the case citing limitation under Section 468 Cr. P.C. The main argument was whether the limitation period should start from the date of collecting samples or the date of the analyst's report. The Court discussed the provisions of Sections 467-473 of the CrPC, focusing on Sections 468 and 469 regarding limitation for different offenses. Section 468 prohibits taking cognizance after the limitation period expires, with different periods based on the offense's punishment. Section 469 deals with the commencement of the limitation period based on the date of the offense or when the offense is known to the aggrieved party or the police. The Court analyzed the facts of the case, determining that the offense was known only after the analyst's report in July 1988, not when the samples were collected. Referring to similar cases in other states, the Court agreed with the interpretation that the limitation period starts from the date of the analyst's report, not the sample collection date. The Court emphasized that the High Court erred in calculating the limitation period from the sample collection date, leading to a miscarriage of justice. Therefore, the Court set aside the High Court's order, allowed the appeal, and remanded the case for further proceedings in accordance with the law. This judgment clarifies the computation of the limitation period for offenses under the Drugs and Cosmetics Act, emphasizing that the limitation starts from when the offense is known, not when the samples are collected. It upholds the importance of following procedural fairness and ensuring justice by correctly interpreting the law's provisions related to limitation periods for criminal cases.
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