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Issues:
1. Interpretation of Section 106 of the Factories Act, 1948 regarding the limitation period for filing a complaint. 2. Determination of whether the report conveyed sufficient knowledge of the commission of an offence under the Act. 3. Analysis of the Inspector's obligation to conduct an inquiry promptly after receiving a report of an accident. Analysis: 1. The Supreme Court analyzed the appeal concerning the judgment of the High Court of Gujarat in a criminal revision application. The issue revolved around the dismissal of a complaint against the Manager of a factory under the Factories Act, 1948, on the grounds of time limitation as per Section 106 of the Act. The High Court set aside the Magistrate's order, leading to the appeal before the Supreme Court. 2. The core question in the case was whether the report received by the Inspector of Factories was adequate to convey knowledge of the offence committed under Section 21(1)(iv)(c) of the Act. The Court examined the details of the accident involving a worker and the dangerous machinery, emphasizing the necessity for the report to encompass all elements of the offence. The Court scrutinized the contents of the report, focusing on whether it explicitly indicated the lack of safety measures in the machinery as required by the Act. 3. The Court delved into the Inspector's duty to promptly inquire into accidents upon receiving a report. The appellant argued that the Inspector should have initiated the inquiry sooner to determine the offence, thereby suggesting that the limitation period for filing a complaint should have commenced earlier. The Court referenced a similar case to elucidate the distinction between knowledge of an accident and knowledge of an offence, emphasizing that the starting point for limitation is the date when the Inspector acquires knowledge of the offence, not when he should have acquired it. The Court affirmed the High Court's decision, dismissing the appeal based on the interpretation of Section 106 and the Inspector's obligation regarding the timing of acquiring knowledge of the offence. In conclusion, the Supreme Court upheld the High Court's ruling, emphasizing the importance of the Inspector's actual knowledge of the offence as the starting point for the limitation period under Section 106 of the Factories Act, 1948. The judgment clarified the requirements for conveying knowledge of an offence through reports and highlighted the significance of timely inquiries by the Inspector to ascertain violations under the Act.
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