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Supreme Court of India 2019-08-23 partly_allowed

Shiv Kumar Jatia vs State of NCT of Delhi

Bench: 2 — R. Subhash Reddy

In Brief

A guest at Hyatt Regency hotel fell from a terrace while smoking and suffered injuries. Criminal proceedings were initiated against the hotel's managing director, general manager, and others under IPC Sections 336/338 (rash/negligent acts endangering life) and COTPA Section 4 (smoking violations). The Supreme Court held that the managing director could not be prosecuted merely because he held the position and attended board meetings—there must be specific evidence of his active role and criminal intent. The Court found allegations against him vague and lacking the necessary nexus. It quashed proceedings against the managing director entirely and partly quashed those against the general manager regarding COTPA violations, allowing other proceedings to continue for trial examination.

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Criminal Procedure Corporate Criminal Liability Directors' Liability Vicarious Liability Section 482 Quashing Negligence Tobacco Regulation

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