( 1 ) THIS is a reference by the Additional Sessions Judge, Allahabad, recommending that the proceedings pending against the applicant for an offence committed against the Factories Act be quashed on the ground that the complaint was not made within three months of the date on which the offence was committed. The relevant facts are that the offence was committed on 13-2-1955 within the knowledge of the Chief Inspector of Factories. He made a complaint of the offence and sent it to the District Magistrate on 22-4-1955 with the request that the Public Prosecutor be directed to present it in the court concerned on or before 12-5-1955, "the last date for making complaint of the offence. " on 13-5-1955 the Sub-Divisional Magistrate Handia took cognizance of the complaint and issued process against the applicant. The applicant appeared and questioned his jurisdiction to take cognizance of the offence on 13-5-1955; his contention was that the last date on which he could take cognizance was 12-5-1955. In reply it was said that the complaint was made before 13-5-1955 (because it was sent by the Chief Inspector to the District Magistrate on 22-4-1955) and this plea was accept