Supreme Court Says Limitation Under S.469 CrPC Begins When Accused’s Identity is Known

The Supreme Court held that the limitation period under Section 469 CrPC begins from the date when the identity of the accused becomes known to the competent authority, not from the date of the initial complaint.

The case arose from prosecution under the Drugs and Cosmetics Act over alleged labelling discrepancies. The Kerala HC had quashed proceedings on limitation grounds.

Setting aside that order, the Court observed that the accused were identified only on April 18, 2006, and the complaint filed on January 20, 2009, was within the three-year limitation period under Section 468 CrPC.

The appeal was accordingly allowed.

[State of Kerala & Anr. v. M/s Panacea Biotec Ltd. & Anr.]