By Harpreet Kaur, Advocate
Introduction:
In the old Criminal Procedure Code, there was no limitation for taking cognizance of an offence. Consequently a prosecution might be launched after the lapse of any period from the date of occurrence. In certain special Acts, a period of limitation for taking cognizance is already prescribed e.g. Section 106 of Indian Factories Act[1]. For the first time in India, the Act of 1978 has enacted some general rules incorporating the law of limitation for taking cognizance of the crimes. It was generally not considered desirable to extend the law of limitation to criminal cases. For, in a criminal prosecution, apart from the injured party and the offender, the community as a whole has an interest in the detection and punishment of the offender and this interest may be defeated if the mere expiry of time is allowed to operate as a bar to prosecution[2]. But the major considerations for prescribing limitation for criminal cases are as follows:
- As the time passes, the testimony of the witnesses becomes weaker and weaker because of lapse of memory and evidence becomes more and more uncertain with the result that the danger of error becomes greater.
- For the purpose of peace and repose, it is necessary that an offender should not be kept under continuous apprehension that he may be prosecuted at any time particularly because with the multifarious laws creating new offences may persons at some time or the other commit some crime or the other. People will have no peace of mind if there is no period of limitation even for petty offences.
- The deterrent effect of punishment is impaired if the prosecution is not launched and punishment is not inflicted before the offence has been wiped off the memory of the person concerned.
- The sense of social retribution which is one of the purposes of criminal law loses its edge after the expiry of a long period.
- The period of limitation would put a pressure on the organs of the criminal prosecution to make every effort to ensure the detection and punishment of the crime quickly[3].
Also the object of the Criminal Procedure Code in putting a bar of limitation on prosecution was clearly to prevent the abuses of the process of Court[4]. Statuses of limitation shut out belated and dormant claims in order to save from the accused from unnecessary harassment. The object which the statutes seek to subserve is clearly in consonance with the concept of fairness of trial as enshrined in Article 21 of the Constitution[5].
The Code has accepted the principle of limitation in respect of less serious offences i.e. offences punishable with fine only or with imprisonment up to three years. It is said that the question of extending the law of limitation to graver offences might be taken up later on in the light of experience actually gained[6].
The provisions regarding limitation are contained in Sections 467- 473 and the accused, depending upon these sections may, in an appropriate case, take the plea that the criminal case against him is barred by the prescribed period of limitation.
Basic rule regarding limitation:
The bar of limitation under the section 468 of the Code of Criminal Procedure, it must be clearly understood, is imposed not on the filing of the complaint but on taking cognizance thereof by the Court[7]. Sub-section (1) of section 468 provides that a court shall not take cognizance of an offence after the expiry of limitation. In section 468, limitation is prescribed for the three classes of offences only-
- Offences punishable with fine only;
- The offences punishable with imprisonment of one year;
- And the offence punishable with imprisonment of three years.
The cognizance can be taken within, six months from the date of commencement specified, if the offence is punishable with fine only; within one year if the offence is punishable with imprisonment of one year and within three years if the offence is punishable with imprisonment for a term exceeding one year but not exceeding three years[8].
The object of Sec. 468 is to put pressure on the organs of the prosecution to make every effort to ensure the detection and punishment of the crime quickly[9].
The bar of limitation is an absolute bar. It goes to the root of jurisdiction of the Court. A court of law cannot take cognizance of an offence, if it is barred by limitation. Delay in filing a complaint petition therefore has to be condoned if the delay is not condoned, the court will have no jurisdiction to take cognizance[10]. Similarly unless it is held that a sanction was not required to be obtained, the court’s jurisdiction will be barred[11].
Mere filing of complaint, a submitting of a police report within the period of limitation is not enough. The Court should take cognizance of the offence within the period of limitation. Suppose a complaint is filed on 6-7-75; but Court makes no order up to 16-1-76. The cognizance is illegal as it was no taken within the period of limitation[12].
Where there was allegation of offence under Essential Commodities Act prescribing maximum sentence of two years but cognizance of offence was taken seven years from the date of occurrence, held that such cognizance was liable to be quashed[13].
The basic rule mentioned above is subject to the other provisions relating to limitation contained elsewhere in the Code. For instance, different periods of limitation have been prescribed for certain offences by Section 198(6) or Section 199(5) and those will not be affected by the basic mentioned above.
Section 468 as it stands today[14] might cause some hardship and injustice to a diligent complainant under certain circumstances. The complainant might have lodged the complaint well in time, but the magistrate receiving the same, instead of taking cognizance of the offence mentioned therein, might send it to the police under Section 156(3) for investigation into the case; and by the time the police report back after the investigation, the period of limitation might have expired or there might be other reasons (for which complainant is not responsible) for not taking cognizance of the offence might get time-barred. Probably, section 473 which gives the discretion to court to extend the period of limitation may, to an extent, be useful to remove the injustice and hardship caused to the complainant in such situations[15].
It is interesting to note that the Supreme Court has ruled that the language of Section 468(3) makes it imperative that the limitation period for taking cognizance in Section 468 is in respect of the offence charged and not in respect of offence finally proved[16].
Where the court takes cognizance of a major offence against an accused person, but finds him guilty of a minor offence, it is open to the accused to plead that conviction for major offence is bad if the complaint or challan is filed against him beyond the power of the court to exercise its discretion under Section 473[17] .
Section 468 imposes a bar on taking cognizance of an offence after the expiry of the period of limitation. Here ‘taking cognizance’ is of offence and not offender. Therefore, if during the pendency of the criminal proceedings, but after the expiry of the period of limitation, the court decides to proceed against some other person as accused person in accordance with the provisions of Section 319, the bar of limitation will not apply in respect of such additional accused persons because even according to the Section 319(4), the case is to proceed against such persons as if they had been accused persons when the court took cognizance of the offence upon which the inquiry or trial was commenced[18]. Moreover, Section 468 starts with “Except as otherwise provided elsewhere in this Code” and Section 319 is one such exception. Therefore, the bar of limitation will not apply to a case where the magistrate proceeds against a person under Section 319[19].
The operation of basic rule has been excluded in respect of certain economic offences by a special law, namely, the Economic Offences (Inapplicability of Limitation) Act, 1974. Section 2 of the Act provides that nothing contained in Sections 467-473 of the Code shall apply to-
- Any offence punishable under any of the enactments specified in the Schedule, or
- Any other offence, which under the provisions of the Code, may be tried along with such offence.
In addition to the above-mentioned Act, there might be State enactments[20] excluding the operation of the periods of limitation as prescribed by the Code, in certain cases. Also, Supreme Court has excluded[21] the operation of limitation in respect of offence under Section 498 A of IPC observing-
“When Section 498 A of the IPC is bought to use in the case cruelty on women, the law of limitation is not that rigid so as to nonsuit the aggrieved wife. A fair dose of liberalities is warranted, so that the law as an instrument comes in aid of the aggrieved due to gender inequalities”.
It has been decided that if there is a conflict between the periods of limitation prescribed in the code and a local law, having regard to Section 4(2) of the Code, the limitation prescribed by local law shall be applicable[22].
Commencement of the period of limitation:
The provisions relating to the commencement of the period of limitation are contained in Sections 469 and 472[23]. Section 469 fixes the date from which the period of limitation in relation to an offender shall commence. As a general rule, the period of limitation begins to run from the date of the commission of the offence and to this general rule, two exceptions are provided by this section. One is where the aggrieved party or police was not aware of the commission of the offence and the second is where the identity of the offender was not known[24]. In computing the limitations, the first day shall be excluded[25].
The exact purpose of clauses (a) (b) and (c) of Section 469 (1)[26] providing three alternatives dates for the commencement of the period of limitation is not easy to understand. The sub-section does not give any specific direction, like “whichever is later” or “whichever is earlier”, for choosing one of the dates. If the choice is to be given to the accused, he will invariably choose clause (a), as that would be most advantageous to him in any case; and in that event clauses (b) and (c) will become superfluous. On the other hand, if the choice is of prosecution, it would always choose clause (c) as that would give longest time to prosecution and in that case, clauses (a) and (b) become redundant. In course of time, these problems will come up before the courts for solution[27].
The term ‘person aggrieved’ has not been defined in the Code. The question whether the term whether the term ‘person aggrieved by the offence’ should be interpreted in a limited and restricted sense meaning one who is personally and directly affected by an offence or should be given wider meaning including any member of the public or even an officer who is charged with the duty of enforcing the prohibitory regulations under statute. It has been held by the Madras High Court[28] that the term ‘person aggrieved by an offence’ should be given limited meaning i.e. one who is personally and directly affected by the offence and not any member of public or even an officer who is charged with the duty of enforcing the prohibitory regulations under statute.
However, as per Batuk Lal’s Commentary on Code of Criminal Procedure, the reasoning of the interpretation of the word given in the judgment is not correct. According to General Clauses Act (Section 42), the term person shall include any company or association or body of individuals, whether incorporated or not. The term ‘aggrieved’ means injured; having a grievance. The cases which have been relied upon in Sulochna’s case are cases of seeking legal remedy by individuals on the breach of public right, they have no application of the cases covered by Section 469. As a matter of law every offence is committed against the State and the State is really aggrieved person in a criminal case. The term person aggrieved includes the Government or an officer who is charged with the duty of the enforcing prohibitory regulations under the statute[29].
Two aspects must be borne in mind: first, the period of limitation is to be considered in relation to an offender; secondly, as held in Tara Dutt[30], the limitation period for taking cognizance in Sec. 468 would be in respect of offence charged and not in respect of the offence finally proved[31]. In the matter of computation of the period of limitation, there are two conflicting views. Not that different High Court have taken different view, conflicting views came from the same High Court. One view is that the relevant date for computation of limitation under sec. 468 is the date of filing of the complaint[32]. The other view is that the relevant date is the date of taking cognizance by the Magistrate[33].
As per B.B. Mitra’s Code of Criminal Procedure, the insurmountable difficulty would be caused if the second view is accepted. The second view may be a legalistic view, but it must fail- and fail it must, when applied to certain circumstances, the possibility of which cannot be ruled out. There is a third view, holding that for the purpose of sec. 468, the date of filing of complaint is the date of taking cognizance. This is again, it is submitted, not correct interpretation of ‘taking of cognizance’.
The controversy has been set at rest by the Supreme Court in Japani Sahoo v. Chandra Sekhar[34], it has been held that ‘for the purpose of computing the period of limitation, the relevant date must be considered as the date of filing of complaint or initiating criminal proceedings and not the date of taking cognizance by the Magistrate or issuance of process by a court’.
According to sec. 472, in case of a continuing offence, a fresh period of limitation shall begin to run every moment of the time during which the offence continues. If the offence is continuing one and continuous at the moment of taking cognizance thereof, then, in view of Section 472, the cognizance will be within limitation irrespective of when the offence came to be committed for the first time or when it first came to the knowledge of the person aggrieved or when the complaint was lodged[35].
A continuing offence is one which is susceptible of continuance and is distinguishable from the one which is committed once and for all[36]. It is one of those offences which arise out of failure to obey or comply with a rule or its requirement and which involves a penalty, the liability for which continues until the rule or its requirement is obeyed or complied with[37]. On every occasion that such disobedience or non-compliance occurs and re-occurs, there is the offence committed[38]. It has been opined that it is not the continuing liability for punishment but the liability for continuing punishment which makes an offence a continuing offence[39].
Continuing offence means an offence that continues from a moment to moment without interruption or break. It is an offence that must continue without requiring any act on the part of the offender to keep it in existence. It is an offence which would come to an end only when the accused does an act to terminate it[40].
Where the breach of statutory duty was an offence then as long as such breach continues, the offence has to be treated to be continues, the offence has to be treated to be continuing[41]. In Bhagirat Kanoria v. State of M.P.[42], the Supreme Court held that non-payment of the employer’s contribution to the Provident Fund before the due date, is a continuing offence and therefore, the period of limitation prescribed in sec. 468 cannot have any application. Also, it was held in Balram Singh v. Sukhwant Kaur[43] that the entrustment of stridhan and the refusal to return it despite repeated requests and persuasions amounts to the offence of criminal breach of trust and is a continuing offence until the return of property to the wife.
Moreover, it was also observed that offences for violation of the provisions of Sections 159 and 220 of the Companies Act are continuing in nature and until and unless the legal requirements contained in the above provisions of the Companies Act are compiled with the persons in charge of the company are liable to be prosecuted. Fresh period of limitation starts on each day until the requirements of the provisions are complied with[44].
Further, the offence of kidnapping for ransom was held to be not abrogated upon the death of victim. There was continuation of ransom calls by the accused even after the death. The offence becomes a continuing offence. The date of last ransom call constitutes the date of offence. By then the accused had attained the age of 18 years. The Juvenile Justice Act ceased to be applicable[45]
Exclusion of time in certain cases:
The provisions relating to exclusion of time in computing the period of limitation are contained in Sections 470 and 471[46]. The principle behind this section 470 is the protection against the bar of limitation person honestly doing his best to get his case tried on merits but failing through, the Court being unable to give him such a trial and this principle is applicable not only to cases the person files his case in the wrong Court, but also where he files his case in his case in the right Court but is nevertheless, prevented from getting a trial on merits by something which, though not a defect in jurisdiction is analogous to that defect[47].
Section 470 (1) provides in reckoning the period of limitation, the time spent in prosecuting another prosecution whether in Court of first instance or appeal or revision shall be excluded provided-
- The first prosecution was prosecuted with due diligence;
- It was against the same accused;
- The prosecution relates to the same fact;
- The prosecution was in good faith;
- And the Court in which the prior case was prosecuted from the defect of the jurisdiction or other case of like nature was unable to entertain it[48]
It was held in the case of S.M. Vikal v. A.L. Chopra[49], the time under this section can be extended when the complainant himself was prosecuting another prosecution. If he himself was prosecuted, the section does not apply.
The question whether or not due care and attention was exercised has to be determined with the reference to the facts of each case. The standard of proof required to adjudge this point cannot be higher than what is laid down in section 3 of the Indian Evidence Act[50]. The real question material for the purpose of section 470 is not whether the complainant was dishonest or that his acts or omissions in this connection were malafide and on the other hand, the question is whether given due care and attention, the complaint could have discovered the mistake earlier[51].
In order that the section 470(1) may apply, it is essential that the Court in which the prior case was prosecuted must have been unable to entertain it due to the defect of jurisdiction or other cause of the like natures[52]. In excluding the time during which former prosecution was pending the day on which that prosecution was instituted and the day on which ended shall both be counted towards the period to be excluded.
Section 470(2) in effect says that in computing the period of limitation where the institution of prosecution has been stayed by an order of injunction or by an order staying the institution of the prosecution[53]. The sub-section (2) requires an order or an injunction which stays the institution of prosecution. If an express order or injunction is produced by a party that clearly meets the requirements of section 470(2) whether the requirements of the sub-section would be satisfied by the production of an order or injunction which is by necessary implications stays the institution of the prosecution is open to argument[54].
Section 470(3) says that where notice of prosecution for an offence has to be given in computing the period of limitation the period of such notice shall be excluded and where in any law the previous consent or sanction of Government or any other authority is required for the prosecution of a person then in computing the period of limitation the time required for consent or sanction including the date on which the application was made and the date of receipt of the order shall be excluded.
It has application only to instances in which notice of prosecution for an offence has been given in accordance with the requirements of any enactment for the time being in force. The law nowhere says to person that when he is under no disability but erroneously imagines himself to be under a disability he will obtain any relaxation of the ordinary law of limitation[55].
Under sub-section (3) where sanction for institution of a prosecution is necessary, the period for obtaining sanction has to be excluded in computing the period of limitation[56]. For instance, for an offence under section 4 of the Dowry Prohibition Act, 1961 the previous sanction of the State Government or of such officer of the State Government as may be specified as essential. Therefore, the time spent in obtaining the sanction is to be excluded[57]
Section 470(4) provides that the period during which the offender is absent from India or any territory outside India which is under the administration of the Central Government or has avoided arrest by absconding or concealing himself shall be excluded from the period of limitation under section 470(4). The burden of proof is upon the person who seeks extension to prove both that the offender has been absent from India and from territories under the administration of Government of India[58].
Section 471 provides that when on the last date of the limitation the Court is closed the cognizance may be taken on the day when the Court reopens. Under the explanation to the section a Court shall be deemed to be closed if during any part of its normal working hours it remains closed on that day. The question whether in any particular case the Court is closed is one of fact which must depend upon the practice which prevails in particular Court[59].
Extension of period of limitation in certain cases:
Section 473 provides that notwithstanding anything contained in the foregoing provisions of this Chapter, any Court may take cognizance of an offence after the expiry of facts and in the circumstances of the case that the delay has been properly explained or that it is necessary so to do in the interests of justice.
The words ‘this chapter’ refer to the Chapter 36 of the Code containing sections 467-473. The section begins with non-obstante clause and if section 468 is read with this section, it would be obvious that while section 468 prohibits the court from taking cognizance of an offence beyond the prescribed period of limitation, section 473 enables the Court to take cognizance after the expiry of the period of limitation in case the court is satisfied that the delay has been properly explained or it is necessary to do so in the interest of justice.
The discretion given to the Court in this connection by section 473 is very wide though it has to be exercised judicially after considering the facts and circumstances of the case[60]. There cannot be any hard and fast rule as to what constitutes sufficient cause to ‘properly explain’ the delay occasioned or what is ‘necessary in the interest of justice’. It must be determined by a reference to the facts and circumstances of the case[61], and it is impossible to encase judicial discretion of the straitjacket[62].
It has been held that the provisions of section 473 should be liberally construed so as to advance substantial justice when no negligence or inaction or want of bonafide is imputable to the prosecutor, but cannot be construed too liberally because the Government is the prosecutor or prosecution is upon the police report[63].
It should also be remembered that the salutary purpose of the law of limitation should not be allowed to be circumvented by taking recourse to the magic words of ‘interests of justice’ unless there is manifestation of compelling and justifiable reasons[64]. Also, when an application is filed by the complainant for the extension of the period of limitation, the principles of natural justice demand that the accused persons must be heard before passing as order on the application as such an order is bound to affect a valuable right which accrues to the accused[65].
Latest cases:
In the case of Ganesh Pal Singh v. State of U.P.[66], it was observed that if the charge-sheet was filed much before the completion of limitation period (three years in this case) then the case is not barred by the limitation.
Brief facts of the case are:- Ganesh Pal Singh is the accused and the matter was investigated and after investigation a Charge-sheet under Section 323, 353, 504 IPC was filed in the court of Magistrate on 3.1.2002 and Magistrate taking cognizance summoned the accused on the same day. The incident took place on 20.9.2001.
Firstly the applicant challenged the summons-order in the court of Sessions Judge which was not accepted. Then again matter went to Magistrate and accused now claimed that the proceedings of the case were barred by time but this plea of accused was rejected by the Magistrate on 27.11.2007 holding that cognizance had already been taken on 3.1.2002. The revision was filed against this order to Addl. Sessions Judge but it was also rejected. Then the revision petition was filed before the High Court.
It was held that the submission of the accused that the cognizance was taken on 27.11.2007 was illegal and without jurisdiction was misconceived. The application has no merits and therefore, deserves to be dismissed.
[1] Batuk lal’s Commentary on Code of Criminal Procedure, Orient Publishing Company (Vol. 2), 2007: 4th ed., p.2540.
[2] K.N. Chandrasekhara Pillai, R. V. Kelkar’s Criminal Procedure, Eastern Book Company, 2011: 5th ed. Reprint, pp.486-487.
[3] Report of the Joint Committee, pp. xxx-xxxi; cited in K.N. Chandrasekhara Pillai, R. V. Kelkar’s Criminal Procedure, Eastern Book Company, 2011: 5th ed. Reprint, p.487.
[4] State of Punjab v. Sarwan Singh, AIR 1981 SC 1054.
[5] Supra note 2, p. 487
[6] 42nd Report of the Law Commission of India on the Indian Penal Code, (1971) p. 346, K.N. Chandrasekhara Pillai, R. V. Kelkar’s Criminal Procedure, Eastern Book Company, 2011: 5th ed. Reprint, p.488.
[7] Woodroffe, Woodroffe Commentaries in Code of Criminal Procedure (Vol. 2), Law Publishers (India) Pvt. Ltd., 2009:3rd ed., p.1908.
[8] Supra note 1, p.2546.
[9] G.D. Iyer,1978 Cri.L.J. 1180 (Del)
[10] Supra note7, p.1908.
[11] P.K. Chaudhary v. Commander, (2008) C.G.L.R. 801 at p. 804 (S.C.)
[12] Supra note 1, p.2547.
[13] Jay Gobind Prasad v. State of Bihar, 2002 Cri.L.J. 4767 (Pat)
[14] In the case of Oriental Bank of Commerce v. DDA (1982 Cri.L.J. 2230), Delhi High Court observed that what the court has to examine is whether on the date of taking cognizance by it, the offence was or was not within the period of limitation prescribed by Section 468.
[15] K.N. Chandrasekhara Pillai, R. V. Kelkar’s Criminal Procedure, Eastern Book Company, 2011: 5th ed. Reprint, p.489.
[16] State of H.P. v. Tara Dutt, (2000) 1 SCC 230.
[17] K. Hanumantha Rao v. K. Narasimha Rao, 1982 Cri.L.J 734. (A.P) (DB)
[18] Sidheshwar Prasad v. State of Bihar, 1979 Cri.L.J. 1411 (Pat)
[19] Basudeo Mandal v. Dud Kumar Pramanick, 1982 Cri.L.J. 1654 (Cal)
[20] For instance, the Maharashtra Acts of 24 of 1976, 44 of 1977 and 22 of 1982.
[21] Vijaya v. Laxmanrao, (1998) 8 SCC 415.
[22] S. Ramachandra Reddy v. P.N. Ravindra Reddy, 1991 Cri.L.J. 1619 (A.P.)
[23]Supra note 15, p.491.
[24] S.N. Misra, The Code of Criminal Procedure, Central Law Publications, 2010: 17th ed., p. 706.
[25] Sub-Section 2 of Section 469.
[26] Sub-section (1) of the Section 469 provides that the period of limitation, in relation to an offender, shall commence either on the date of the offence; or where the commission of the offence is not known to the person aggrieved by the offence or to any police-officer, the first day on which such offence comes to the knowledge of such person or any police officer, whichever is earlier; or where it is not known by whom the offence was committed, the first day on which the identity of the offender is known to the person aggrieved by the offence or police officer making investigation into the offence, whichever is earlier.
[27] Supra note 15, p.492.
[28] .., 1978 Cri.L.J. 116 (Mad)
[29] Supra note 1, p. 2557.
[30] AIR 2000 SC 297.
[31] B.B. Mitra, Code of Criminal Procedure, Kamal Law House (Vol. 2), 2011: 21st ed., p. 2560.
[32] Hari Jai Singh v. Suresh Kumar Gupta, 2004 Cri.L.J, 3768 (HP)
[33] Court on its own motion v. Sh. Shankroo, 1983 Cri.L.J. 63 (HP)
[34] (2007) 7 SCC 394.
[35] Oriental Bank of Commerce v. DDA, 1982 Cri.L.J. 2230 at 2233 (Del)
[36] Supra note 1, p.2563.
[37]Supra note 2, p.494.
[38] State of Bihar v. Deokaran Nenshi, (1972) 2 SCC 890
[39] See discussions in Ramnugaar Cane & Sugar Co. Ltd. v. Asstt. Registrar of Companies, 1989 Cri.L.J. 2395 (Cal)
[40] Supra note 1, p.2563.
[41] S. Irani (Sorkhas) v. M/s. Dinshaw & Dinshaw, 1999 Cri.L.J. 240 (Bom)
[42] AIR 1980 SC 1688
[43] 1992 Cri.L.J. 792 (P&H)
[44] Rani Joseph v. Registrar of Companies, 1995 Cri.L.J. 3832 (Ker)
[45] Vikas Chaudhary v. State of NCT, Delhi, AIR 2010 SC 3380
[46] Supra note 2, p.495.
[47] Kamta Prasad v. Ram Narayan, AIR 1957 Pat 139
[48] (Firm) Lal Chand Nathumal v. Firm Balram Rameshwar, AIR 1957 MP 95
[49] 1978 Cri.L.J 764 (SC)
[50] Ibid.
[51] Madho Rao v. Ram Krishna, AIR 1958 SC 767
[52] Sunni Central Board of Waqf v. Sirajul Haq, AIR 1954 All 88
[53] Woodroffe, Woodroffe Commentaries in Code of Criminal Procedure (Vol. 2), Law Publishers (India) Pvt. Ltd., 2009:3rd ed., p.1920.
[54] Siraj-ul-Haq Khan v. Sunni Central Board of Waqf, Uttar Pradesh, AIR 1959 SC 198
[55] Ladli Prasad v. Nizamuddin Khan, AIR 1919 Oudh 26
[56] Punjab Beverages v. State, 1980 Cri.L.J. NOC 134 (Punj)
[57] Lajpat Rai v. State, 1983 Cri.L.J. 888 (Del)
[58] Ezra Sion v. Kailas Viriah, AIR 1937 Bom 242
[59] Ramani Ramji v. T. Maniah, AIR 1959 AP 103
[60] K. Hanumantha Rao v. K. Narasimha Rao, 1982 Cri.L.J. 734
[61] A.K. Thaga Pillai v. Supdt., Regulated Market of the South Arcot Market Committee, 1977 Cri.L.J. 1375 (Mad)
[62] G.D. Iyer v. State, 1978 Cri.L.J. 1180 (Del)
[63] Krishna Sanghi v. State of M.P., 1977 Cri.L.J. 90 (MP)
[64] S.K. Bajaj v. D.K. Bhattacharya, 1982 Cri.L.J. 210 (Cal)
[65] Appu Rmani v. State, 1993 Cri.L.J. 1974 (AP)
[66] 2011 Cri.L.J 3350 (All)
[67] 1996)(1) SCC 345 (p 351)
[68] 2000 (1) FLR 759
[69] AIR 1965 SC 1827
[70] 1984 (3) SCC 14
[71] 2000 (4) SCC 126
LawSchoolNotes 
is limitation provision came into crpc in 1978?
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No sir, sections 467-473 were there in CRPC 1973
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