As per case facts, a Drugs Inspector filed a complaint against Panacea Biotec Ltd. for drug misbranding. The CJM summoned the company, but the High Court later quashed the proceedings, ... stating the CJM failed to conduct a mandatory inquiry under Section 202 CrPC because the accused resided outside its territorial jurisdiction. The High Court did not address limitation. The appeal to the Supreme Court challenged the High Court's quashing order, arguing Section 202 CrPC inquiry is not mandatory for public servant complaints, and the delay was justified. The question arose whether Section 202 CrPC's mandatory inquiry applies to public servant complaints when the accused lives outside the Magistrate's jurisdiction, and how limitation under Section 469 CrPC is calculated in such cases. Finally, the Supreme Court ruled that the limitation period started when the offender's identity was established, making the complaint within time. It also held that the Section 202 CrPC inquiry is not mandatory for public servant complaints acting in official duty, harmonizing with Section 200 CrPC. Consequently, the High Court's order was set aside, and the summoning order was restored. The linked appeal by the accused was dismissed.