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Holds No Knowledge for Culpable Homicide in Lifelong Factory Fire
Chandigarh : In a significant ruling, the has partially allowed a petition seeking in connection with the 2024 factory fire at Lifelong India in Dharuhera, which resulted in multiple deaths and injuries. Justice Virinder Aggarwal set aside charges under Sections 304 Part II () and (), holding that the material on record did not establish the requisite knowledge likely to cause death. However, the court upheld the prosecution under Sections 287 () and 304-A (), directing the trial court to frame fresh charges.
The Incident and Initial Charges
On , a fire broke out at the Lifelong India factory in Dharuhera, District Rewari. According to the FIR, complainant Raj Kumar alleged that a boiler dust collector burst due to negligence by the company owners, officers and the contractor in maintaining equipment and keeping an emergency gate closed. Initially, the FIR was registered under Sections 287, 337 and 34 . As several injured workers succumbed, the police added Sections 308 and 304 Part II .
The , framed charges on , under Sections 287, 304 Part II, , and in the alternative . The petitioners—Parmod Kumar Yadav and others—challenged this order under (corresponding to ), seeking , final report and the charge order.
Arguments: A Tale of Two Versions
Senior counsel for the petitioners argued that the occurrence was an unfortunate industrial accident caused by technical factors like an electrical fault and accumulation of combustible dust. They relied on two expert reports—one by the and another by the Deputy Director, Industrial Safety & Health. Both reports independently attributed the fire to a spark generated in a buffing machine, not a boiler burst. The factory was operating with statutory permissions, they contended, and any alleged safety lapses fell within the special regime of the . They further submitted that the trial court had framed charges on without assessing each accused's individual role.
The State countered that the material—including statements of injured witnesses, medical evidence and the deaths— showed serious lapses. It argued that the Factories Act did not bar prosecution under the for distinct offences involving loss of life, and that the precise role of each petitioner could only be determined at trial.
Court Rips Trial Court for Discarding Expert Report
The High Court found serious infirmity in the trial court's approach towards the report and CCTV footage. The trial court had discarded the expert report on the ground that it had not been formally proved. Justice Aggarwal termed this an "" of standards.
"The wholesale rejection of the 's report and the CCTV footage, merely because the former had not been formally proved in accordance with the rules of evidence and the latter had not, at that stage, been subjected to the complete evidentiary process, amounts to an of the standard applicable at the stage of trial with that governing consideration of charge."
He noted that the
is an expert body with specialised expertise, and its findings were substantially corroborated by the CCTV footage, which captured the fire originating from a buffing machine—not a boiler. The court observed that these materials
"materially undermine the foundational premise of the prosecution version regarding the occurrence of a boiler blast."
No Case for Culpable Homicide
Applying the 's decision in (the Bhopal Gas Tragedy case), the High Court held that a charge under requires material showing that the accused acted with knowledge that the act was likely to cause death. In Keshub Mahindra , the had held that mere operation of a defective plant dealing with toxic MIC does not by itself show such knowledge.
The High Court also referred to its own decision in
(2006), where a charge was altered to Section 304-A despite a pharmaceutical unit running without statutory approvals and a locked emergency exit that caused seven deaths. The court had held that the material did not disclose knowledge that the act was
"so imminently dangerous that it must, in all probability, cause death."
Applying these principles, the High Court concluded:
"At the highest, the material on record may warrant consideration of the offences punishable under Sections 287 and 304-A ."
Argument Rejected
The petitioners argued that since a separate complaint under
had been filed for the same incident, a parallel
prosecution was impermissible. The court rejected this, noting that the Factories Act complaint was filed only against the factory's alleged occupier and manager, Sh. Sandeep Bhat, and not against the petitioners. The court held that
"the protection against
necessarily operates in relation to the person who has already been prosecuted and punished for the same offence,"
and the mere pendency of proceedings against a different accused does not extinguish the petitioners' liability.
Final Order: Charges Reduced to Negligence
Partly allowing the petition, the court set aside the charges under Sections 304 Part II and against all petitioners. It directed the Additional Sessions Judge to frame fresh charges under Sections 287 and 304-A , specifically setting out the particulars of both the injured and deceased workers—since the existing charge lacked such details. The case will then be committed to the for trial.
The court clarified that its observations were confined to the charge stage and were not an expression on the merits of the prosecution case. The ruling reinforces the principle that , courts must consider all investigation material—including expert reports—without requiring , and must strictly assess whether the ingredients of graver offences like culpable homicide are made out.
