S.M. Datta, the occupier of a factory in Gujarat, was accused of violating Section 63 of the Factories Act, 1948, after a Factory Inspector found a worker on duty beyond ... the prescribed hours. Datta argued that the overtime work was lawful and sought to quash the complaints, claiming they were filed maliciously. Both the Gujarat High Court and the Supreme Court rejected his petitions, holding that the allegations required proper investigation and that criminal proceedings should not be prematurely terminated unless they constituted an abuse of process.