S.M. DATTA versus STATE OF GUJARAT AND ANR.
Quashing criminal complaints at the investigation stage should be rare and only in cases of abuse of process; here, alleged non-compliance with Form No. 14 and entry 'beforehand' needs further investigation, so complaint should not be quashed.
- Parties
- Appellant: S.M. Datta; Respondents: State of Gujarat and Anr.
- Jurisdiction
- India
- Judgment Date
- 24 August 2001
- Procedural Posture
- Criminal Appeal / Appeal From Dismissal of Criminal Revision Petition by Gujarat High Court at Investigation Stage
- Outcome
- Appeals dismissed
- Legal Topics
- Quashing of Criminal Proceedings, Factory Compliance, Investigation Powers Under Cr PC
Case Brief
Summary, issues, holding and outcome
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Parties
S.M. Datta
Appellant
State of Gujarat and Anr.
Respondents
Procedural Posture
Criminal Appeal / Appeal From Dismissal of Criminal Revision Petition by Gujarat High Court at Investigation Stage
Legal Issues
- 1 Whether criminal proceedings under Factories Act, 1948 can be quashed at the investigation stage
- 2 Interpretation of Sections 61, 62, 63 of Factories Act regarding display of notice and maintenance of registers
Ratio Decidendi
Quashing criminal complaints at the investigation stage should be rare and only in cases of abuse of process; here, alleged non-compliance with Form No. 14 and entry 'beforehand' needs further investigation, so complaint should not be quashed.
Court Disposition
Appeals dismissed
Orders
- No order as to costs
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