Varinder Singh vs State Of Punjab & Anr

The Supreme Court held that the appellant could not be charged under Sections 42 and 45 of the Prisons Act, 1894, as he was not a prisoner at the time of the alleged offence. The Court found that Section 45(12) pertains to prison offences committed by prisoners, and since the appellant was merely a visitor, no offence was made out. Consequently, the Court quashed the High Court's dismissal of the FIR and ruled that the appellant's actions did not violate the provisions of the Act.