Criminal limitation barred prosecution where sanction-related delay was not properly pleaded and time exclusion could not be claimed.

Complaints alleging offences punishable with imprisonment not exceeding one year were subject to the one-year limitation period under Section 468 CrPC, and the prosecutions were initiated after substantial delay. Although Section 470 CrPC permits exclusion of time spent obtaining sanction, the complaints failed to state when sanction was sought or granted, so no exclusion of time could be claimed. A belated assertion of later knowledge could not cure the limitation defect, and incorrect citation of provisions did not alter the substance of the challenge. The prosecutions were therefore barred by limitation and could not be sustained.

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Issues: Whether the complaints and consequent criminal prosecutions were barred by limitation under the Code of Criminal Procedure, 1973, and whether the absence of particulars regarding sanction and the period required for obtaining it prevented exclusion of time so as to save the prosecution.

Analysis: The complaints disclosed alleged offences punishable with imprisonment not exceeding one year, so the period of limitation under Section 468 of the Code of Criminal Procedure, 1973 was one year. The complaints were lodged only after a substantial delay from the alleged violations. Although Section 470 of the Code of Criminal Procedure, 1973 permits exclusion of the time taken for obtaining sanction, the complaints did not state when sanction was sought or when it was granted. In the absence of those essential particulars, the complainant could not claim exclusion of time. The Court also held that a prosecution launched in disregard of the statutory limitation cannot be sustained by a belated assertion of later knowledge, and that wrong quoting of provisions in some petitions did not affect the real nature of the challenge.

Conclusion: The prosecutions were barred by limitation and could not be sustained.

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