In Brief
On 5 January 1996, a roof collapse at Kusunda Colliery killed four workers and injured five others. The Director of Mines Safety prosecuted seven colliery officials under the Mines Act for violating Systematic Support Rules. The trial court convicted all seven; the High Court upheld the convictions. The Supreme Court held: (1) Manager Binoy Kumar Mishra and Agent Madhusudan Banerjee's convictions were sustainable—the prosecution discharged its initial burden by showing violations of SSR; their failure to prove due diligence supported guilt. Sentences were modified to fines only, considering age and circumstances. (2) General Manager and Additional General Manager Mahendra Prasad Gupta and Nageshwar Sharma were not formally appointed as agents and the prosecution failed to substantiate their participation in management/supervision. Their convictions were set aside as no specific violation was proved against them.
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