State Of UP vs jagdeep heera — 314/2024

Summary The court allowed the state's criminal revision petition against a factory accident case. The trial court had dismissed a complaint filed under the Factories Act, 1948 on the ground that it was filed beyond the statutory three-month limitation period. However, the revisional court found that the complaint was actually filed on 27.06.2023, within three months of the incident date (01.04.2023), and that the trial court erred in using a delayed filing date. Applying the Supreme Court principle from *Japani Sahoo v. Chandra Sekhar Mohanty*, the court held that a complainant cannot be penalized for court delays in taking cognizance, and the relevant date for limitation is the complaint filing date, not the cognizance date. The trial court's dismissal order was set aside and the matter remitted for fresh adjudication. This case analysis is maintained by casestatus.in based on publicly available court records.