Ajeet Vikram Bahadur Singh Vs State of Maharashtra (Bombay High Court)
In the case of Ajeet Vikram Bahadur Singh v. State of Maharashtra, the Bombay High Court quashed an FIR filed under the IPC against the manager of Pidilite Industries following a factory accident. The incident involved a blaze from a machine that caused injuries to a worker. The manager had already been convicted and fined under Section 92 of the Factories Act, 1948, for negligence in maintaining machinery. The court ruled that prosecuting the manager under IPC sections 285, 287, 337, and 338 constituted double jeopardy, as the offenses under both statutes arose from the same facts and had overlapping elements.
The court referenced Article 20(2) of the Constitution and Section 300 of the CrPC, which prohibit double prosecution for the same offense. It noted that the manager’s prior conviction under the Factories Act addressed the same negligence, thus barring further proceedings under the IPC.
Relying on established legal precedents, Bombay High Court held that once criminal complaint has been lodged by the Factory Inspector, the police lose their jurisdiction to investigate the same matter and to file a separate chargesheet arising out of the same incident. The Bombay Accordingly, the court quashed the FIR and dismissed the case under the IPC.
