STATE OF GUJARAT vs KANSARA MANILAL BHIKHALAL

The Supreme Court held that the respondent, as the occupier/manager of a factory, was not exempt from liability under Section 63 of the Factories Act, 1948 due to a failure to notify changes in working hours as required by Section 61(1). The Court clarified that Section 61(10) pertains to changes affecting the overall system of work and does not excuse individual infractions. Additionally, the protection under Section 117 is only available for actions taken in compliance with the Act, not for actions contrary to it, thus affirming the conviction of the respondent.