MANEKLAL JINABHAI KOT vs STATE OF GUJARAT & ORS.

The Supreme Court held that under Section 101 of the Factories Act, 1948, a manager can be absolved from liability if he proves due diligence in enforcing the Act and that the actual offenders committed the offence without his consent, knowledge, or connivance. The Court found that the appellant had taken necessary precautions and was not present during the commission of the offence, leading to the conclusion that he should be discharged while the salesman and supervisor, who pleaded guilty, should be convicted. The judgment of the Gujarat High Court was thus set aside.