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Supreme Court of India 2017-03-31 partly_allowed

Binoy Kumar Mishra vs State of Jharkhand and Another

Bench: 2 — A.K. Sikri

In Brief

In January 1996, a roof collapse at a coal mine in Jharkhand killed four workers and injured five others. The trial court convicted all seven mine employees, including four public servants (manager, agent, and two senior officials), under the Mines Act for violating safety regulations. The Supreme Court upheld the convictions of the manager and agent, finding they failed to ensure compliance with Systematic Support Rules despite bearing statutory responsibility. However, the Court set aside convictions of the General Manager and Additional General Manager, holding that they could not be deemed 'agents' without specific evidence of active participation in mine management. The Court also reduced sentences for the convicted manager and agent from imprisonment to fines only, considering the incident's age, negligence rather than deliberate wrongdoing, and the accused's personal circumstances including advanced age and health issues."

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Criminal Law Mines Act Occupational Safety Strict Liability Negligence Environmental Law Accident Liability

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