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Varaj Lall vs Emperor on 15 April, 1924

8. Judicial authority is overwhelmingly in favour of such a view. As early as 1924, the Calcutta High Court in Varaj Lall v. Emperor AIR 1924 Cal. 985 while construing the corresponding provisions of the Motor Vehicles Act 1914 pointed out, "Where a particular intent or state of mind is not of the essence of the offence, a master can be criminally liable for the servant's acts if the act is expressly prohibited, but not otherwise; and he cannot be so made liable if the act provides for liability for permitting and causing a certain thing unless it can be shown that the act was done with the master's knowledge and assent express or implied".
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