P. D. JAMBEKAR vs STATE OF GUJARAT

The Supreme Court held that under Section 106 of the Factories Act, 1948, the limitation period for taking cognizance of an offence begins when the Inspector gains knowledge of the commission of the offence, not merely the accident. The Court found that the report did not provide sufficient information to conclude that an offence under Section 21(iv)(c) had been committed, thus the Inspector only acquired knowledge of the offence during the inquiry on July 30, 1968. Consequently, the High Court's decision to set aside the Magistrate's dismissal of the complaint was upheld.