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Issues Involved:
1. Judicial interference in police investigations. 2. Disclosure of a cognizable offence in the First Information Report (FIR). 3. Compliance with statutory provisions under the Factories Act, 1948. 4. Grounds for quashing a complaint at the initial stage. Issue-wise Detailed Analysis: 1. Judicial Interference in Police Investigations: The judgment emphasizes the principle established since the Privy Council's decision in Khwaja Nazir Ahmed, which states that courts should not interfere with police investigations unless the case falls under exceptional circumstances. The court reiterated that the police have the statutory right to investigate cognizable offences without requiring judicial authority. This principle is based on the complementary functions of the judiciary and the police, where the judiciary intervenes only when a charge is formally presented before it. 2. Disclosure of a Cognizable Offence in the FIR: The court highlighted that if an FIR discloses a cognizable offence, the investigation must proceed. However, if no offence is disclosed, the police have no authority to investigate. This principle was affirmed in cases like Sanchaita Investment and Bhajan Lal. The court underscored that the liberty and property of individuals are sacred and must be protected from unnecessary harassment through unwarranted investigations. 3. Compliance with Statutory Provisions under the Factories Act, 1948: The court examined the statutory requirements under the Factories Act, 1948, specifically Sections 61, 62, and 63. These sections mandate maintaining a notice of periods of work for adults and a register of adult workers. The complaint alleged that the factory violated Section 63 by allowing a worker to work beyond prescribed hours without proper entries in the attendance register. The court noted that compliance with these provisions is crucial for protecting workers' rights and ensuring their welfare. 4. Grounds for Quashing a Complaint at the Initial Stage: The court reiterated that quashing a complaint at the initial stage is an exception rather than the rule. Criminal proceedings should not be halted unless the complaint is an abuse of the court's process. The court emphasized that the FIR should be read as a whole to determine if it discloses an offence. The court found that the complaint in question did not warrant quashing at this stage as it required further investigation to ascertain compliance with the statutory provisions. Conclusion: The Supreme Court dismissed the appeals, emphasizing that the complaints should not be quashed at the initial stages unless they constitute an abuse of the court's process. The court held that the matter required further investigation to determine compliance with the Factories Act, 1948, and thus, there was no justification for interfering with the High Court's order.
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