Bharat Damodar Kale v. State of Andhra Pradesh, (2003) 8 SCC 559 and Japani Sahoo v. Chandra Sekhar Mohanty, (2007) 7 SCC 394 as against Krishna Pillai v. T.A. Rajendran, 1990 (Supp.) SCC 121 was Referred to a Three Judge Bench which in turn Referred to a Larger Bench.

Sarah Mathew v. Institute of Cardio Vascular Diseases, (2014) 2 SCC 62 has to be understood in light of situations which were dealt with. It is clear, though Section 468 mandates ‘cognizance’ ought to be taken within specified period from commission of offence, this Court ruled: a complainant should not be put to prejudice, if for reasons beyond control of prosecuting agency or complainant, ‘cognizance’ was taken after period of limitation. It was observed, if filing of complaint or initiation of proceedings was within prescribed period from date of commission of an offence, Court would be entitled to take ‘cognizance’ even after prescribed period was over.

– Hon’ble Justice U.U. Lalit, Kamatchi v. Lakshmi Naryanan, [Criminal Appeal No. 627 of 2022].