Substantial compliance with statutory accident notice held sufficient where written notice was impossible and purpose of the requirement was met.

The amended electricity law required notice of an accident in the prescribed form and within the prescribed time, and the earlier notification fixing those particulars continued in force under Section 24 of the General Clauses Act because it was not inconsistent with the re-enacted provision and had not been superseded. The continued notification was treated as law in force for criminal liability, so the Article 20 challenge failed. On the facts, immediate knowledge of the accident's time, place, nature and probable cause reached the Electrical Inspector, and a written notice within 24 hours was impossible because the injured persons were unavailable. The court treated this as substantial compliance and regarded literal written notice as an idle formality.

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Issues: Whether the notice requirement relating to an accident under the amended electricity law was enforceable through the pre-amendment notification continued by the General Clauses Act, and whether the communication made to the Electrical Inspector amounted to substantial compliance despite the absence of a written notice within 24 hours.

Analysis: The re-enacted provision required notice in the prescribed form and within the prescribed time, and the earlier notification fixing the time, form, and particulars continued in force under Section 24 of the General Clauses Act so long as it was not inconsistent with the re-enacted provision and not expressly superseded. The continued notification was treated as a law in force on the date of the accident, and the argument based on Article 20 of the Constitution of India failed. On the facts, the Electrical Inspector and his assistant had immediate knowledge of the time, place, nature, and probable cause of the accident, while the exact cause could not be ascertained within the stipulated time because the injured persons were unavailable. Requiring a written notice in those circumstances would have been insistence on an impossible or idle formality, and the object of the requirement had otherwise been met.

Conclusion: The accused had substantially complied with the notice requirement and had not committed the alleged offence.

Ratio Decidendi: A notification continued in force by Section 24 of the General Clauses Act remains a law in force for the purposes of criminal liability, and where the substance of a statutory notice requirement is complied with but literal compliance is impossible or idle, the law treats the requirement as satisfied.

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