Himachal Pradesh High Court, in Anurag Singh and Anr. vs. State of Himachal Pradesh Through Labour Inspector (Cr. MMO No. 165/2025),on June 6, 2025 examined the legality of criminal proceedings initiated by a factory inspector against an employer under the Factories Act, 1948 (“Factories Act”). The Court, after reviewing the case, quashed both the complaint and all consequential proceedings, citing non-compliance with the statutory limitation period prescribed under Section 106 of the Factories Act. In doing so, the Court relied on its earlier decision in Saugata Gupta vs. State of H.P. (2019 SCC OnLine HP 1672), which emphasised that the 3-month limitation period for filing complaints under the Factories Act is mandatory and must be strictly adhered to.
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