J.J.Irani & Anr vs State Of Jharkhand

The Supreme Court examined the applicability of Section 106 of the Factories Act, 1948, which mandates that complaints regarding offences must be made within three months of the knowledge of the offence. The Court held that the complaint by the Inspector of Factories was not filed within the stipulated time frame, thus rendering the proceedings against the appellants invalid. Consequently, the Court reversed the High Court's order and upheld the Chief Judicial Magistrate's decision, emphasizing the importance of adhering to statutory timelines in prosecuting offences under the Act.