Dola Singh vs Ltd & Anr on 29 July, 2026

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    Himachal Pradesh High Court

    Dola Singh vs Ltd & Anr on 29 July, 2026

                                                                                            2026:HHC:31278
    
        IN THE HIGH COURT OF HIMACHAL PRADESH, SHIMLA
    
    
                                                  Cr. Revision No. 58 of 2025
                                                  Reserved on: 21.07.2026
    
    
    
    
                                                                                       .
                                                  Date of Decision: 29.07.2026
    
    
    
    
    
        Dola Singh                                                                   ...Petitioner
    
    
    
    
    
                                                 Versus
        H.P. State Co-operative Agriculture and Rural Development Bank
    
    
    
    
                                                         of
        Ltd & Anr.                                      ...Respondents
        _______________________________________
        Coram                  rt
        Hon'ble Mr Justice Rakesh Kainthla, Judge.
        Whether approved for reporting?1 No
    
        For the Petitioner                                 :      Mr N.K. Bhardwaj, Advocate.
        For Respondent No.1                               :       Mr Narender Singh Thakur,
                                                                  Advocate.
    
    
    
        For Respondent No.2/State                         :       Mr Tarun Pathak, Deputy
                                                                  Advocate General.
    
    
    
    
        Rakesh Kainthla, Judge
    

    The present revision is directed against the judgment

    dated 15.01.2025 passed by the learned Sessions Judge, Kullu,

    SPONSORED

    District Kullu, H.P. (learned Appellate Court) vide which the

    judgment of conviction and order of sentence dated 01.05.2024

    passed by the learned Judicial Magistrate First Class, Banjar, District

    Kullu HP (learned Trial Court) were upheld. (The parties shall

    1 Whether reporters of Local Papers may be allowed to see the judgment? Yes.

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    hereinafter be referred to in the same manner as they were arrayed

    before the learned Trial Court for convenience).

    2. Briefly stated, the facts giving rise to the present revision

    .

    are that the complainant filed a complaint before the learned Trial

    Court against the accused for the commission of an offence

    punishable under Section 138 of the Negotiable Instruments Act (NI

    Act). It was asserted that the complainant is a cooperative society

    of
    and is engaged in banking activities. The accused availed a loan of

    ₹10,00,000/- from the complainant and issued a cheque of
    rt
    ₹95,000/- to partly repay the amount borrowed by him. The

    complainant presented the cheque at its bank, but it was

    dishonoured with the remarks “funds insufficient”. The

    complainant sent a legal notice to the accused asking him to pay the

    money within 15 days of the receipt of the notice. The notice was

    duly served upon the accused, but the accused failed to repay the

    loan. Hence, a complaint was filed before the Court for taking action

    against the accused.

    3. The learned Trial Court found sufficient reasons to

    summon the accused. When the accused appeared, a notice of

    accusation was put to him for the commission of an offence

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    punishable under Section 138 of the NI Act, to which he pleaded not

    guilty and claimed trial.

    4. The complainant examined Dhale Ram (CW1) to prove its

    .

    complaint.

    5. The accused, in his statement, recorded under Section 313

    of the Code of Criminal Procedure (Cr.P.C), denied the complainant’s

    of
    case in its entirety. He examined himself (DW1) in his defence.

    6. The learned Trial Court held that the accused had not
    rt
    disputed the issuance of the cheque and his signatures. Therefore, a

    presumption applied that the cheque was issued for consideration to

    discharge the debt/liability. The burden was upon the accused to

    rebut the presumption, but he failed to produce any evidence to

    rebut the presumption. The cheque was dishonoured with

    endorsement “insufficient funds”. The notice was duly served upon

    the accused, and he failed to repay the money. Hence, the learned

    Trial Court convicted the accused of the commission of an offence

    punishable under Section 138 of the NI Act and sentenced him to

    undergo simple imprisonment for 2 months and pay a compensation

    of ₹1,00,000/-.

    7. Being aggrieved by the judgment and order passed by the

    learned Trial Court, the accused filed an appeal which was decided by

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    the learned Sessions Judge Kullu, District Kullu, HP (learned

    Appellate Court). The learned Appellate Court concurred with the

    findings recorded by the learned Trial Court that the accused had not

    .

    disputed the issuance of the cheque, and a presumption applied that

    the cheque was issued for consideration to discharge the

    debt/liability. The complainant failed to rebut the presumption by

    producing any evidence. The plea taken by the accused that the

    of
    complaint was not filed by the proper officer was not sustainable

    because an authority letter issued by the Managing Director in
    rt
    favour of the complainant of Branch Manager was placed on record.

    The Branch Manager is also a Principal Officer and competent to file

    the complaint. The cheque was dishonoured with endorsement

    “insufficient funds”. The notice was duly served upon the accused,

    and the accused failed to repay the money. Hence, all the ingredients

    of the commission of an offence punishable under Section 138 of the

    NI Act were duly satisfied. Learned Trial Court had imposed an

    adequate sentence and no interference was required with the

    judgment and order passed by the learned Trial Court. Consequently,

    the appeal was dismissed.

    8. Being aggrieved by the judgments and order passed by

    the learned Courts below, the accused has filed the present revision,

    asserting that the learned Courts below failed to appreciate the

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    material placed before them. The complainant had misused the

    security cheque taken at the time of advancing the loan. No authority

    letter was placed on record to show that the Branch Manager was

    .

    authorised to file the complaint. No ledger was placed on record to

    prove the exact liability of the accused. Therefore, it was prayed that

    the present revision be allowed and the judgments and order passed

    by learned Courts below be set aside.

    of

    9. I have heard Mr N.K. Bharadwaj, learned counsel for the

    petitioner/accused, Mr Narinder Singh Thakur, learned counsel for
    rt
    respondent no. 1 and Mr Tarun Pathak, learned Deputy Advocate

    General for the respondent no. 2/State.

    10. Mr N.K. Bharadwaj, learned counsel for the

    petitioner/accused submitted that learned Courts below failed to

    appreciate the material placed before them. The defence taken by the

    accused that the cheque was issued as a security which was misused

    by the complainant was highly probable from the statement of the

    accused. The complainant has not placed the authority of the Branch

    Manager to file the complaint, and the complaint was not

    maintainable. The notice did not mention the name of the person on

    whose behalf the notice was issued, and the notice was defective.

    Hence, he prayed that the present revision be allowed and the

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    judgments and order passed by learned Courts below be set aside. He

    relied upon the judgments in Jaipur Thar Gramin Bank, Branch

    Jaisalmer vs. State 2022(1) Civil Court Cases 668 (Rajasthan) and

    .

    Mansa Central Co-operative Bank Ltd vs. Lachhman Singh 2023(4)

    Civil Court Cases 460 (P&H) in support of his submission.

    11. Mr Narinder Singh Thakur, learned counsel for the

    respondent No.1 submitted that the testimony of Dhale Ram (CW1)

    of
    that he was authorised to file the complaint was not challenged in

    the cross-examination and this plea cannot be taken before this
    rt
    Court. The accused had not disputed the issuance of the cheque and

    learned Courts below had rightly applied presumption to the present

    case. All the ingredients of the commission of the offence punishable

    under Section 138 of the NI Act were duly satisfied. There is no

    infirmity in the judgments and order passed by learned Courts below

    and this Court should not re-appreciate the evidence while deciding

    the present revision. Hence, he prayed that the present revision be

    dismissed. He relied upon the judgment of this Court in Kewal Ram

    vs. HP Cooperative Agriculture and Rural Development Bank Ltd.

    2026:HHC:10810 in support of his submissions.

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    12. Mr Tarun Pathak, learned Deputy Advocate General for

    the State submitted that the dispute is between the private persons

    and the State has no submissions to make.

    .

    13. I have given considerable thought to the submissions

    made at the bar and have gone through the records carefully.

    14. It was laid down by the Hon’ble Supreme Court in

    of
    Malkeet Singh Gill v. State of Chhattisgarh, (2022) 8 SCC 204: (2022) 3

    SCC (Cri) 348: 2022 SCC OnLine SC 786 that a revisional court is not an
    rt
    appellate court and it can only rectify the patent defect, errors of

    jurisdiction or the law. It was observed at page 207-

    “10. Before adverting to the merits of the contentions, at the
    outset, it is apt to mention that there are concurrent findings

    of conviction arrived at by two courts after a detailed
    appreciation of the material and evidence brought on record.
    The High Court in a criminal revision against conviction is not

    supposed to exercise the jurisdiction like the appellate court,
    and the scope of interference in revision is extremely narrow.

    Section 397 of the Criminal Procedure Code (in short “CrPC“)
    vests jurisdiction to satisfy itself or himself as to the
    correctness, legality or propriety of any finding, sentence or

    order, recorded or passed, and as to the regularity of any
    proceedings of such inferior court. The object of the provision
    is to set right a patent defect or an error of jurisdiction or law.
    There has to be a well-founded error that is to be determined
    on the merits of individual cases. It is also well settled that
    while considering the same, the Revisional Court does not
    dwell at length upon the facts and evidence of the case to
    reverse those findings.

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    15. This position was reiterated in State of Gujarat v. Dilipsinh

    Kishorsinh Rao, (2023) 17 SCC 688: 2023 SCC OnLine SC 1294, wherein

    it was observed at page 695:

    .

    “14. The power and jurisdiction of the Higher Court under
    Section 397 CrPC, which vests the court with the power to call
    for and examine records of an inferior court, is for the

    purposes of satisfying itself as to the legality and regularities
    of any proceeding or order made in a case. The object of this
    provision is to set right a patent defect or an error of

    of
    jurisdiction or law or the perversity which has crept in such
    proceedings.

    15. It would be apposite to refer to the judgment of this Court
    in Amit Kapoor v. Ramesh Chander [Amit Kapoor v. Ramesh
    rt
    Chander, (2012) 9 SCC 460: (2012) 4 SCC (Civ) 687: (2013) 1 SCC
    (Cri) 986], where scope of Section 397 has been considered and

    succinctly explained as under: (SCC p. 475, paras 12-13)
    “12. Section 397 of the Code vests the court with the
    power to call for and examine the records of an inferior

    court for the purposes of satisfying itself as to the
    legality and regularity of any proceedings or order made
    in a case. The object of this provision is to set right a

    patent defect or an error of jurisdiction or law. There has
    to be a well-founded error, and it may not be

    appropriate for the court to scrutinise the orders, which,
    upon the face of it, bear a token of careful consideration
    and appear to be in accordance with law. If one looks

    into the various judgments of this Court, it emerges that
    the revisional jurisdiction can be invoked where the
    decisions under challenge are grossly erroneous, there is
    no compliance with the provisions of law, the finding
    recorded is based on no evidence, material evidence is
    ignored, or judicial discretion is exercised arbitrarily or
    perversely. These are not exhaustive classes, but are
    merely indicative. Each case would have to be
    determined on its own merits.

    13. Another well-accepted norm is that the revisional
    jurisdiction of the higher court is a very limited one and

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    cannot be exercised in a routine manner. One of the inbuilt
    restrictions is that it should not be against an interim or
    interlocutory order. The Court has to keep in mind that the
    exercise of revisional jurisdiction itself should not lead to
    injustice ex facie. Where the Court is dealing with the question

    .

    as to whether the charge has been framed properly and in

    accordance with law in a given case, it may be reluctant to
    interfere in the exercise of its revisional jurisdiction unless the
    case substantially falls within the categories aforestated. Even

    the framing of the charge is a much-advanced stage in the
    proceedings under CrPC.”

    16. It was held in Kishan Rao v. Shankargouda, (2018) 8 SCC

    of
    165: (2018) 3 SCC (Cri) 544: (2018) 4 SCC (Civ) 37: 2018 SCC OnLine SC

    651 that it is impermissible for the High Court to reappreciate the
    rt
    evidence and come to its conclusions in the absence of any

    perversity. It was observed at page 169:

    “12. This Court has time and again examined the scope of

    Sections 397/401 CrPC and the grounds for exercising the
    revisional jurisdiction by the High Court. In State of Kerala v.
    Puttumana Illath Jathavedan Namboodiri
    , (1999) 2 SCC 452:

    1999 SCC (Cri) 275], while considering the scope of the
    revisional jurisdiction of the High Court, this Court has laid

    down the following: (SCC pp. 454-55, para 5)

    5. … In its revisional jurisdiction, the High Court can call

    for and examine the record of any proceedings to satisfy
    itself as to the correctness, legality or propriety of any
    finding, sentence or order. In other words, the
    jurisdiction is one of supervisory jurisdiction exercised
    by the High Court for correcting a miscarriage of justice.

    But the said revisional power cannot be equated with the
    power of an appellate court, nor can it be treated even as
    a second appellate jurisdiction. Ordinarily, therefore, it
    would not be appropriate for the High Court to
    reappreciate the evidence and come to its conclusion on
    the same when the evidence has already been

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    appreciated by the Magistrate as well as the Sessions
    Judge in appeal, unless any glaring feature is brought to
    the notice of the High Court which would otherwise
    amount to a gross miscarriage of justice. On scrutinising
    the impugned judgment of the High Court from the

    .

    aforesaid standpoint, we have no hesitation in

    concluding that the High Court exceeded its jurisdiction
    in interfering with the conviction of the respondent by
    reappreciating the oral evidence. …”

    13. Another judgment which has also been referred to and
    relied on by the High Court is the judgment of this Court in
    Sanjaysinh Ramrao Chavan v. Dattatray Gulabrao Phalke, (2015)

    of
    3 SCC 123: (2015) 2 SCC (Cri) 19]. This Court held that the High
    Court, in the exercise of revisional jurisdiction, shall not
    interfere with the order of the Magistrate unless it is perverse
    or wholly unreasonable or there is non-consideration of any
    rt
    relevant material; the order cannot be set aside merely on the
    ground that another view is possible. The following has been

    laid down in para 14: (SCC p. 135)
    “14. … Unless the order passed by the Magistrate is perverse or
    the view taken by the court is wholly unreasonable or there is

    non-consideration of any relevant material or there is
    palpable misreading of records, the Revisional Court is not
    justified in setting aside the order, merely because another

    view is possible. The Revisional Court is not meant to act as an
    appellate court. The whole purpose of the revisional

    jurisdiction is to preserve the power in the court to do justice
    in accordance with the principles of criminal jurisprudence.
    The revisional power of the court under Sections 397 to 401

    CrPC is not to be equated with that of an appeal. Unless the
    finding of the court, whose decision is sought to be revised, is
    shown to be perverse or untenable in law or is grossly
    erroneous or glaringly unreasonable or where the decision is
    based on no material or where the material facts are wholly
    ignored or where the judicial discretion is exercised arbitrarily
    or capriciously, the courts may not interfere with the decision
    in exercise of their revisional jurisdiction.”

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    17. This position was reiterated in Bir Singh v. Mukesh Kumar,

    (2019) 4 SCC 197: (2019) 2 SCC (Cri) 40: (2019) 2 SCC (Civ) 309: 2019

    SCC OnLine SC 13, wherein it was observed at page 205:

    .

    “16. It is well settled that in the exercise of revisional
    jurisdiction under Section 482 of the Criminal Procedure Code,
    the High Court does not, in the absence of perversity, upset

    concurrent factual findings. It is not for the Revisional Court
    to re-analyse and re-interpret the evidence on record.

    17. As held by this Court in Southern Sales & Services v.

    of
    Sauermilch Design and Handels GmbH, (2008) 14 SCC 457, it is a
    well-established principle of law that the Revisional Court will
    not interfere even if a wrong order is passed by a court having
    jurisdiction, in the absence of a jurisdictional error. The
    rt
    answer to the first question is, therefore, in the negative.”

    18. A similar view was taken in Sanjabij Tari v. Kishore S.

    Borcar, 2025 SCC OnLine SC 2069, wherein it was observed:

    “27. It is well settled that in exercise of revisional jurisdiction,
    the High Court does not, in the absence of perversity, upset
    concurrent factual findings [See: Bir Singh(supra)]. This Court

    is of the view that it is not for the Revisional Court to re-
    analyse and re-interpret the evidence on record. As held by

    this Court in Southern Sales & Services v. Sauermilch Design and
    Handels GMBH
    , (2008) 14 SCC 457, it is a well-established
    principle of law that the Revisional Court will not interfere,

    even if a wrong order is passed by a Court having jurisdiction,
    in the absence of a jurisdictional error.

    28. Consequently, this Court is of the view that in the absence
    of perversity, it was not open to the High Court in the present
    case, in revisional jurisdiction, to upset the concurrent
    findings of the Trial Court and the Sessions Court.

    19. The present revision has to be decided as per the

    parameters laid down by the Hon’ble Supreme Court.

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    20. The ingredients of the offence punishable under Section

    138 of the NI Act were explained by the Hon’ble Supreme Court in

    Kaveri Plastics v. Mahdoom Bawa Bahrudeen Noorul, 2025 SCC OnLine

    .

    SC 2019 as under: –

    “5.1.1. In K.R. Indira v. Dr. G. Adinarayana (2003) 8 SCC 300, this

    Court enlisted the components, aspects and the acts, the
    concatenation of which would make the offence under Section
    138
    of the Act complete, to be these (i) drawing of the cheque

    of
    by a person on an account maintained by him with a banker,
    for payment to another person from out of that account for
    discharge in whole/in part of any debt or liability, (ii)
    presentation of the cheque by the payee or the holder in due
    rt
    course to the bank, (iii) returning the cheque unpaid by the
    drawee bank for want of sufficient funds to the credit of the

    drawer or any arrangement with the banker to pay the sum
    covered by the cheque, (iv) giving notice in writing to the
    drawer of the cheque within 15 days of the receipt of
    information by the payee from the bank regarding the return

    of the cheque as unpaid, demanding payment of the cheque
    amount, and (v) failure of the drawer to make payment to the
    payee or the holder in due course of the cheque, of the amount

    covered by the cheque, within 15 days of the receipt of the
    notice.”

    21. The accused Dola Singh (DW1), stated that he had applied

    for a house loan of ₹10,00,000/-. He was asked to produce a cheque

    book. He opened the account and handed over the blank cheques to

    the Manager. The cheques did not contain any amount or the date.

    He had not handed over any cheque after taking the loan. The cheque

    (Ext.CW1/B) was blank without any date or without any amount. The

    date and the amount were filled by the Manager. He admitted in his

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    cross-examination that he had taken a loan of ₹10,00,000/- from

    the bank. He also admitted his signature on the cheque (Ext.CW1/B).

    He admitted that he had received the notice but had not sent any

    .

    reply to it. He admitted that he had mortgaged his land to take a

    loan.

    22. It is apparent from the testimony of this witness that he

    has admitted the issuance of the cheque and his signatures on the

    of
    cheque. It was laid down by the Hon’ble Supreme Court in APS Forex

    Services (P) Ltd. v. Shakti International Fashion Linkers (2020) 12 SCC
    rt
    724, that when the issuance of a cheque and signature on the cheque

    are not disputed, a presumption would arise that the cheque was

    issued in discharge of the legal liability. It was observed: –

    “9. Coming back to the facts in the present case and
    considering the fact that the accused has admitted the

    issuance of the cheques and his signature on the cheque and
    that the cheque in question was issued for the second time

    after the earlier cheques were dishonoured and that even
    according to the accused some amount was due and payable,

    there is a presumption under Section 139 of the NI Act that
    there exists a legally enforceable debt or liability. Of course,
    such a presumption is rebuttable. However, to rebut the
    presumption, the accused was required to lead evidence that
    the full amount due and payable to the complainant had been
    paid. In the present case, no such evidence has been led by the
    accused. The story put forward by the accused that the
    cheques were given by way of security is not believable in the
    absence of further evidence to rebut the presumption, and
    more particularly, the cheque in question was issued for the
    second time after the earlier cheques were dishonoured.
    Therefore, both the courts below have materially erred in not

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    properly appreciating and considering the presumption in
    favour of the complainant that there exists a legally
    enforceable debt or liability as per Section 139 of the NI Act. It
    appears that both the learned trial court as well as the High
    Court have committed an error in shifting the burden upon

    .

    the complainant to prove the debt or liability, without

    appreciating the presumption under Section 139 of the NI Act.
    As observed above, Section 139 of the Act is an example of a
    reverse onus clause and therefore, once the issuance of the

    cheque has been admitted and even the signature on the
    cheque has been admitted, there is always a presumption in
    favour of the complainant that there exists legally enforceable

    of
    debt or liability and thereafter, it is for the accused to rebut
    such presumption by leading evidence.”

    23. This position was reiterated in N. Vijay Kumar v.

    rt
    Vishwanath Rao N., 2025 SCC OnLine SC 873, wherein it was held as

    under:

    “6. Section 118 (a) assumes that every negotiable instrument
    is made or drawn for consideration, while Section 139 creates

    a presumption that the holder of a cheque has received the
    cheque in discharge of a debt or liability. Presumptions under
    both are rebuttable, meaning they can be rebutted by the

    accused by raising a probable defence.”

    24. A similar view was taken in Sanjabij Tari v. Kishore S.

    Borcar, 2025 SCC OnLine SC 2069, wherein it was observed:

    “ONCE EXECUTION OF A CHEQUE IS ADMITTED, PRESUMPTIONS
    UNDER SECTIONS 118 AND 139 OF THE NI ACT ARISE

    15. In the present case, the cheque in question has admittedly
    been signed by the Respondent No. 1-Accused. This Court is of
    the view that once the execution of the cheque is admitted, the
    presumption under Section 118 of the NI Act that the cheque in
    question was drawn for consideration and the presumption
    under Section 139 of the NI Act that the holder of the cheque
    received the said cheque in discharge of a legally enforceable
    debt or liability arises against the accused. It is pertinent to

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    mention that observations to the contrary by a two-Judge
    Bench in Krishna Janardhan Bhat v. Dattatraya G. Hegde, (2008)
    4 SCC 54, have been set aside by a three-Judge Bench in
    Rangappa (supra).

    16. This Court is further of the view that by creating this

    .

    presumption, the law reinforces the reliability of cheques as a

    mode of payment in commercial transactions.

    17. Needless to mention that the presumption contemplated
    under Section 139 of the NI Act is rebuttable. However, the

    initial onus of proving that the cheque is not in discharge of
    any debt or other liability is on the accused/drawer of the
    cheque [See: Bir Singh v. Mukesh Kumar, (2019) 4 SCC 197].

    of

    25. Thus, the Court has to start with the presumption that

    the cheque was issued in discharge of the liability for consideration,
    rt
    and the burden is upon the accused to rebut this presumption.

    26. The accused admitted that he had taken the loan of

    ₹10,00,000/- in the year 2017. He has nowhere stated that he had

    repaid the loan. The cheque of ₹95,000/- was issued on 07.08.2021,

    and in the absence of any proof of the repayment of the loan, the

    complainant’s version is acceptable that the accused was liable to

    pay an amount of ₹95,000/-. Therefore, learned Courts below had

    rightly held that the accused was liable. It was laid down by this

    Court in Hamid Mohammad Versus Jaimal Dass 2016 (1) HLJ 456, that

    the accused is liable for the dishonour of the cheque even if the

    cheque is issued towards the security. It was observed:

    “9. Submission of learned Advocate appearing on behalf of the
    revisionist that the cheque in question was issued to the
    complainant as security, and on this ground, the criminal

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    revision petition is rejected as being devoid of any force for the
    reasons hereinafter mentioned. As per Section 138 of the
    Negotiable Instruments Act, 1881, if any cheque is issued on
    account of other liability, then the provisions of Section 138 of
    the Negotiable Instruments Act, 1881 would be attracted. The

    .

    court has perused the original cheque, Ext. C-1 dated

    30.10.2008, placed on record. There is no recital in the cheque
    Ext. C-1 that the cheque was issued as a security cheque. It is
    well-settled law that a cheque issued as security would also

    come under the provisions of Section 138 of the Negotiable
    Instruments Act, 1881. See 2016 (3) SCC page 1 titled Don
    Ayengia v. State of Assam & another
    . It is well-settled law that

    of
    where there is a conflict between former law and subsequent
    law, then subsequent law always prevails.”

    27. It was laid down by the Hon’ble Supreme Court in

    Sampelly
    rt
    Satyanarayana Rao vs. Indian Renewable Energy

    Development Agency Limited, 2016(10) SCC 458 that issuing a cheque

    toward security will also attract the liability for the commission of

    an offence punishable under Section 138 of the NI Act. It was

    observed: –

    “10. We have given due consideration to the submission

    advanced on behalf of the appellant as well as the
    observations of this Court in Indus Airways Private Limited
    versus Magnum Aviation Private Limited
    (2014) 12 SCC 53 with

    reference to the explanation to Section 138 of the Act and the
    expression “for the discharge of any debt or other liability”

    occurring in Section 138 of the Act. We are of the view that the
    question of whether a post-dated cheque is for “discharge of
    debt or liability” depends on the nature of the transaction. If
    on the date of the cheque, liability or debt exists or the amount
    has become legally recoverable, the Section is attracted and not
    otherwise.

    11. Reference to the facts of the present case clearly shows that
    though the word “security” is used in clause 3.1(iii) of the

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    agreement, the said expression refers to the cheques being
    towards repayment of instalments. The repayment becomes
    due under the agreement the moment the loan is advanced,
    and the instalment falls due. It is undisputed that the loan was
    duly disbursed on 28th February 2002, which was prior to the

    .

    date of the cheques. Once the loan was disbursed and

    instalments had fallen due on the date of the cheque as per the
    agreement, the dishonour of such cheques would fall under
    Section 138 of the Act. The cheques undoubtedly represent the

    outstanding liability.

    12. Judgment in Indus Airways (supra) is clearly
    distinguishable. As already noted, it was held therein that

    of
    liability arising out of a claim for breach of contract under
    Section 138, which arises on account of dishonour of a cheque
    issued, was not by itself at par with a criminal liability
    towards discharge of acknowledged and admitted debt under a
    rt
    loan transaction. Dishonour of a cheque issued for the
    discharge of a later liability is clearly covered by the statute in

    question. Admittedly, on the date of the cheque, there was a
    debt/liability in praesenti in terms of the loan agreement, as
    against the case of Indus Airways (supra), where the purchase
    order had been cancelled, and a cheque issued towards

    advance payment for the purchase order was dishonoured. In
    that case, it was found that the cheque had not been issued for
    the discharge of liability but as an advance for the purchase

    order, which was cancelled. Keeping in mind this fine, but the
    real distinction, the said judgment cannot be applied to a case

    of the present nature, where the cheque was for repayment of
    a loan instalment which had fallen due, though such a deposit

    of cheques towards repayment of instalments was also
    described as “security” in the loan agreement. In applying the
    judgment in Indus Airways (supra), one cannot lose sight of
    the difference between a transaction of the purchase order
    which is cancelled and that of a loan transaction where the
    loan has actually been advanced, and its repayment is due on
    the date of the cheque.

    13. The crucial question to determine the applicability of
    Section 138 of the Act is whether the cheque represents the
    discharge of existing enforceable debt or liability, or whether
    it represents an advance payment without there being a

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    subsisting debt or liability. While approving the views of
    different High Courts noted earlier, this is the underlying
    principle as can be discerned from the discussion of the said
    cases in the judgment of this Court.” (Emphasis supplied)

    28. This position was reiterated in Sripati Singh v. State of

    .

    Jharkhand, 2021 SCC OnLine SC 1002: AIR 2021 SC 5732, and it was

    held that a cheque issued as security is not waste paper and a

    complaint under section 138 of the NI Act can be filed on its

    of
    dishonour. It was observed:

    “17. A cheque issued as security pursuant to a financial
    transaction cannot be considered a worthless piece of paper
    rt
    under every circumstance. ‘Security’ in its true sense is the
    state of being safe, and the security given for a loan is

    something given as a pledge of payment. It is given, deposited
    or pledged to make certain the fulfilment of an obligation to
    which the parties to the transaction are bound. If in a
    transaction, a loan is advanced and the borrower agrees to

    repay the amount in a specified timeframe and issues a cheque
    as security to secure such repayment; if the loan amount is not
    repaid in any other form before the due date or if there is no

    other understanding or agreement between the parties to
    defer the payment of the amount, the cheque which is issued

    as security would mature for presentation and the drawee of
    the cheque would be entitled to present the same. On such a

    presentation, if the same is dishonoured, the consequences
    contemplated under Section 138 and the other provisions of
    the NI Act would flow.

    18. When a cheque is issued and is treated as ‘security’ towards
    repayment of an amount with a time period being stipulated
    for repayment, all that it ensures is that such a cheque, which
    is issued as ‘security ‘, cannot be presented prior to the loan or
    the instalment maturing for repayment towards which such
    cheque is issued as security. Further, the borrower would have
    the option of repaying the loan amount or such financial
    liability in any other form, and in that manner, if the amount

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    of the loan due and payable has been discharged within the
    agreed period, the cheque issued as security cannot thereafter
    be presented. Therefore, the prior discharge of the loan or
    there being an altered situation due to which there would be
    an understanding between the parties is a sine qua non to not

    .

    present the cheque which was issued as security. These are

    only the defences that would be available to the drawer of the
    cheque in proceedings initiated under Section 138 of the NI
    Act. Therefore, there cannot be a hard and fast rule that a

    cheque, which is issued as security, can never be presented by
    the drawee of the cheque. If such is the understanding, a
    cheque would also be reduced to an ‘on-demand promissory

    of
    note’, and in all circumstances, it would only be civil litigation
    to recover the amount, which is not the intention of the
    statute. When a cheque is issued even though as ‘security’ the
    consequence flowing therefrom is also known to the drawer of
    rt
    the cheque and in the circumstance stated above if the cheque
    is presented and dishonoured, the holder of the

    cheque/drawee would have the option of initiating the civil
    proceedings for recovery or the criminal proceedings for
    punishment in the fact situation, but in any event, it is not for
    the drawer of the cheque to dictate terms with regard to the

    nature of litigation.”

    29. Therefore, the accused cannot escape from the liability by

    taking a plea that he had issued the cheque as security.

    30. The accused claimed that he had not filled the cheque and

    the manager had filled it. This plea will not help the accused. It has

    already been found out above that the accused had taken a loan of

    ₹10,00,000/- from the complainant and he has not led any evidence

    to show the return of the amount. Therefore, the plea taken by the

    complainant that he had a subsisting liability of ₹95,000/- is

    acceptable. Thus, the complainant had sufficient authority to fill the

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    amount of ₹95,000/- and present the cheque. It was laid down by

    the Hon’ble Supreme Court in Bir Singh v. Mukesh Kumar, (2019) 4

    SCC 197: (2019) 2 SCC (Cri) 40: (2019) 2 SCC (Civ) 309: 2019 SCC OnLine

    .

    SC 138, that a person is liable for the commission of an offence

    punishable under section 138 of the Negotiable Instruments Act even

    if some other person fills the cheque. It was observed:

    “33. A meaningful reading of the provisions of the Negotiable

    of
    Instruments Act
    , including, in particular, Sections 20, 87 and
    139, makes it amply clear that a person who signs a cheque
    and makes it over to the payee remains liable unless he
    rt
    adduces evidence to rebut the presumption that the cheque
    had been issued for payment of a debt or in discharge of a
    liability. It is immaterial that the cheque may have been filled

    in by any person other than the drawer if the cheque is duly
    signed by the drawer. If the cheque is otherwise valid, the
    penal provisions of Section 138 would be attracted.

    34. If a signed blank cheque is voluntarily presented to a
    payee, towards some payment, the payee may fill in the
    amount and other particulars. This in itself would not

    invalidate the cheque. The onus would still be on the accused
    to prove that the cheque was not in discharge of a debt or

    liability by adducing evidence.

    35. It is not the case that the respondent accused him of either

    signing the cheque or parting with it under any threat or
    coercion. Nor is it the case that the respondent accused that
    the unfilled signed cheque had been stolen. The existence of a
    fiduciary relationship between the payee of a cheque and its
    drawer would not disentitle the payee to the benefit of the
    presumption under Section 139 of the Negotiable Instruments
    Act, in the absence of evidence of exercise of undue influence
    or coercion. The second question is also answered in the
    negative.

    36. Even a blank cheque leaf, voluntarily signed and handed
    over by the accused, which is towards some payment, would

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    attract presumption under Section 139 of the Negotiable
    Instruments Act, in the absence of any cogent evidence to
    show that the cheque was not issued in discharge of a debt.”

    31. This position was reiterated in Oriental Bank of Commerce

    .

    v. Prabodh Kumar Tewari, 2022 SCC OnLine SC 1089, wherein it was

    observed:

    “12. The submission, which has been urged on behalf of the
    appellant, is that even assuming, as the first respondent
    submits, that the details in the cheque were not filled in by the

    of
    drawer, this would not make any difference to the liability of
    the drawer.

    xxxxxx
    rt

    32. A drawer who signs a cheque and hands it over to the payee
    is presumed to be liable unless the drawer adduces evidence to

    rebut the presumption that the cheque has been issued
    towards payment of a debt or in the discharge of a liability.
    The presumption arises under Section 139.

    32. Therefore, the cheque is not bad even if it is not filled in

    by the drawer.

    33. Dhale Ram (CW1) specifically stated in his proof affidavit

    (Ext.CW1/A) that he was a Branch Manager conversant with the facts

    of the case and duly authorised to file the complaint on behalf of the

    bank. He was not cross-examined regarding this fact. No question

    was asked of him about his authority to file the complaint before the

    Court. Thus, his testimony that he was competent to file the

    complaint had remained unrebutted. It was laid down by the Hon’ble

    Supreme Court in State of Uttar Pradesh Versus Nahar Singh, 1998 (3)

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    SCC 561 that where the testimony of a witness is not challenged in

    the cross-examination, the same cannot be challenged during the

    arguments. This position was reiterated in Arvind Singh v. State of

    .

    Maharashtra, (2021) 11 SCC 1: (2022) 1 SCC (Cri) 208: 2020 SCC OnLine

    SC 4, and it was held at page 34:

    “58. A witness is required to be cross-examined in a criminal
    trial to test his veracity; to discover who he is and what his
    position in life is, or to shake his credit, by injuring his

    of
    character, although the answer to such questions may directly
    or indirectly incriminate him or may directly or indirectly
    expose him to a penalty or forfeiture (Section 146 of the
    rt
    Evidence Act). A witness is required to be cross-examined to
    bring forth inconsistencies and discrepancies, and to prove

    the untruthfulness of the witness. A-1 set up a case of his
    arrest on 1-9-2014 from 18:50 hrs; therefore, it was required
    for him to cross-examine the truthfulness of the prosecution
    witnesses with regard to that particular aspect. The argument

    that the accused was shown to be arrested around 19:00 hrs is
    an incorrect reading of the arrest form (Ex. 17). In Column 8, it
    has been specifically mentioned that the accused was taken

    into custody on 2-9-2014 at 14:30 hrs at Wanjri Layout, Police
    Station, Kalamna. The time, i.e. 17, 10 hrs, mentioned in

    Column 2, appears to be when A-1 was brought to the Police
    Station, Lakadganj. As per the IO, A-1 was called for
    interrogation as the suspicion was on an employee of Dr

    Chandak since the kidnapper was wearing a red colour t-shirt
    which was given by Dr Chandak to his employees. A-1
    travelled from the stage of suspect to an accused only on 2-9-
    2014. Since no cross-examination was conducted on any of
    the prosecution witnesses about the place and manner of the
    arrest, the argument that the accused was arrested on 1-9-
    2014 at 18:50 hrs is not tenable.

    59. The House of Lords, in a judgment reported as Browne v.
    Dunn (1893) 6 R 67 (HL), considered the principles of
    appreciation of evidence. Lord Chancellor Herschell held that
    it is essential to the proper conduct of a cause, where it is

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    intended to suggest that a witness is not speaking the truth on
    a particular point, to direct his attention to the fact by some
    questions put in cross-examination showing that imputation
    is intended to be made, and not to take his evidence and pass
    it by as a matter altogether unchallenged. It was held as

    .

    under:

    “Now, my Lords, I cannot help saying that it seems to me
    to be absolutely essential to the proper conduct of a cause,
    where it is intended to suggest that a witness is not

    speaking the truth on a particular point, to direct his
    attention to the fact by some questions put in cross-
    examination showing that that imputation is intended to

    of
    be made, and not to take his evidence and pass it by as a
    matter altogether unchallenged, and then, when it is
    impossible for him to explain, as perhaps he might have
    been able to do if such questions had been put to him, the
    rt
    circumstances which it is suggested indicate that the story
    he tells ought not to be believed, to argue that he is a

    witness unworthy of credit. My Lords, I have always
    understood that if you intend to impeach a witness you are
    bound, whilst he is in the box, to give him an opportunity
    of making any explanation which is open to him; and, as it

    seems to me, that is not only a rule of professional practice
    in the conduct of a case, but is essential to fair play and fair
    dealing with witnesses. Sometimes reflections have been

    made upon excessive cross-examination of witnesses, and
    it has been complained of as undue, but it seems to me that

    cross-examination of a witness which errs in the direction
    of excess may be far more fair to him than to leave him

    without cross-examination, and afterwards, to suggest
    that he is not a witness of truth, I mean upon a point on
    which it is not otherwise perfectly clear that he has had full
    notice beforehand that there is an intention to impeach the
    credibility of the story which he is telling.”

    60. Lord Halsbury, in a separate but concurring opinion, held as
    under:

    “My Lords, with regard to the manner in which the
    evidence was given in this case, I cannot too heartily
    express my concurrence with the Lord Chancellor as to the
    mode in which a trial should be conducted. To my mind,

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    nothing would be more absolutely unjust than not to
    cross-examine witnesses upon evidence which they have
    given, so as to give them notice, and to give them an
    opportunity of explanation, and an opportunity very often
    to defend their own character, and, not having given them

    .

    such an opportunity, to ask the jury afterwards to

    disbelieve what they have said, although not one question
    has been directed either to their credit or to the accuracy of
    the facts they have deposed to.”

    61. This Court, in a judgment reported as State of U.P. v. Nahar Singh,
    (1998) 3 SCC 561: 1998 SCC (Cri) 850, quoted from Browne v. Dunn,
    (1893) 6 R 67 (HL) to hold that in the absence of cross-examination

    of
    on the explanation of delay, the evidence of PW 1 remained
    unchallenged and ought to have been believed by the High Court.
    Section 146 of the Evidence Act confers a valuable right of cross-
    examining the witness tendered in evidence by the opposite party.

    rt
    This Court held as under: (State of U.P. v. Nahar Singh, (1998) 3 SCC
    561: 1998 SCC (Cri) 850], SCC pp. 566-67, para 13)

    “13. It may be noted here that part of the statement of PW 1
    was not cross-examined by the accused. In the absence of
    cross-examination on the explanation of the delay, the

    evidence of PW 1 remained unchallenged and ought to have
    been believed by the High Court. Section 138 of the
    Evidence Act confers a valuable right of cross-examining

    the witness tendered in evidence by the opposite party. The
    scope of that provision is enlarged by Section 146 of the

    Evidence Act by allowing a witness to be questioned:

    (1) to test his veracity,

    (2) to discover who he is and what his position in life is,
    or
    (3) to shake his credit by injuring his character,
    although the answer to such questions might tend
    directly or indirectly to incriminate him or might
    expose or tend directly or indirectly to expose him to a
    penalty or forfeiture.”

    62. This Court, in a judgment reported Muddasani Venkata Narsaiah
    v. Muddasani Sarojana
    , (2016) 12 SCC 288: (2017) 1 SCC (Civ) 268, laid
    down that the party is obliged to put his case in cross-examination
    of witnesses of the opposite party. The rule of putting one’s version

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    in cross-examination is one of essential justice and not merely a
    technical one. It was held as under: (SCC pp. 294-95, paras 15-16)
    “15. Moreover, there was no effective cross-examination
    made on the plaintiff’s witnesses with respect to the
    factum of execution of the sale deed. PW 1 and PW 2 have

    .

    not been cross-examined as to the factum of execution of

    the sale deed. The cross-examination is a matter of
    substance, not of procedure. One is required to put one’s
    own version in the cross-examination of the opponent.

    The effect of non-cross-examination is that the statement
    of the witness has not been disputed. The effect of not
    cross-examining the witnesses has been considered by this

    of
    Court in Bhoju Mandal v.Debnath Bhagat, AIR 1963 SC 1906.
    This Court repelled a submission on the ground that the
    same was not put either to the witnesses or suggested
    before the courts below. A party is required to put his
    rt
    version to the witness. If no such questions are put, the
    Court would presume that the witness account has been

    accepted as held in Chuni Lal Dwarka Nath v. Hartford Fire
    Insurance Co. Ltd.
    , 1957 SCC OnLine P&H 177: AIR 1958 P&H

    440.

    16. In Maroti Bansi Teli v. Radhabai, 1943 SCC OnLine MP
    128: AIR 1945 Nag 60, it has been laid down that the matters
    sworn to by one party in the pleadings not challenged

    either in pleadings or cross-examination by another party
    must be accepted as fully established. The High Court of

    Calcutta in A.E.G. Carapiet v. A.Y. Derderian, 1960 SCC OnLine
    Cal 44: AIR 1961 Cal 359 has laid down that the party is
    obliged to put his case in the cross-examination of

    witnesses of the opposite party. The rule of putting one’s
    version in cross-examination is one of essential justice and
    not merely a technical one. A Division Bench of the Nagpur
    High Court, Kuwarlal Amritlal v. Rekhlal Koduram, 1949 SCC
    OnLine MP 35: AIR 1950 Nag 83 has laid down that when
    attestation is not specifically challenged, and the witness is
    not cross-examined regarding details of attestation, it is
    sufficient for him to say that the document was attested. If
    the other side wants to challenge that statement, it is their
    duty, quite apart from raising it in the pleadings, to cross-
    examine the witness along those lines. A Division Bench of

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    the Patna High Court in Karnidan Sardav.Sailaja Kanta
    Mitra, 1940 SCC OnLine Pat 288: AIR 1940 Pat 683 has laid
    down that it cannot be too strongly emphasised that the
    system of administration of justice allows of cross-
    examination of opposite party’s witnesses for the purpose

    .

    of testing their evidence, and it must be assumed that

    when the witnesses were not tested in that way, their
    evidence is to be ordinarily accepted. In the aforesaid
    circumstances, the High Court has gravely erred in law in

    reversing the findings of the first appellate court as to the
    factum of execution of the sale deed in favour of the
    plaintiff.”

    of

    34. Therefore, it was rightly submitted on behalf of the

    complainant that this plea could not have been raised before the Ld.
    rt
    appellate Court, and it is impermissible to raise this plea before this

    Court as well. In Jaipur Thar Gramin Bank (supra), the accused had

    disputed the authority of the manager to file the complaint, which is

    not the case here. Hence, the cited judgment does not apply to the

    present case.

    35. The accused admitted taking of the loan, and there is no

    evidence that the loan was repaid. Therefore, it was duly proved that

    the cheque was issued for repayment of the debt taken by the

    accused.

    36. Dhale Ram (CW1) stated that the cheque was presented

    before the bank and it was dishonoured with endorsement

    “insufficient funds”. He has filed the copy of the cheque return

    memo. (Ext.CW1/E) which shows that the reason for dishonour was

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    “funds insufficient”. It was laid down by the Hon’ble Supreme Court

    in Mandvi Cooperative Bank Ltd. v. Nimesh B. Thakore, (2010) 3 SCC

    83: (2010) 1 SCC (Civ) 625: (2010) 2 SCC (Cri) 1: 2010 SCC OnLine SC 155

    .

    that the memo issued by the Bank is presumed to be correct and the

    burden is upon the accused to rebut the presumption. It was

    observed at page 95:

    “24. Section 146, making a major departure from the

    of
    principles of the Evidence Act, provides that the bank’s slip or
    memo with the official mark showing that the cheque was
    dishonoured would, by itself, give rise to the presumption of
    rt
    dishonour of the cheque, unless and until that fact was
    disproved. Section 147 makes the offences punishable under
    the Act compoundable.”

    37. In the present case, the accused has not stated in his

    statement that he had sufficient funds in his account and the cheque

    was wrongly dishonoured by the bank. Therefore, learned Courts

    below had rightly held that the cheque was dishonoured with an

    endorsement “funds insufficient”.

    38. Dhale Ram (CW1) stated that the complainant had issued

    a notice (Ext.CW1/D) to the accused, asking him to pay the money

    within 15 days of the receipt of the notice. He filed the

    acknowledgement (Ext.CW1/G). The accused, Dola Singh (DW1),

    admitted in his cross-examination that he had received the notice

    and the acknowledgement (Ext.CW1/G) is signed by him. Therefore,

    the service of notice upon the accused was duly proved.

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    39. It was submitted that the name of the persons on whose

    behalf the notice was issued was not mentioned in the notice, and

    the notice is bad. This submission is only stated to be rejected. It was

    .

    specifically stated in the notice (Ext.CW1/D) that the notice was

    issued on behalf of HP State Co-operative Bank, Agricultural and

    Rural Development Bank Ltd., Branch Banjar. The cheque was also

    issued in the name of Himachal Pradesh Cooperative Agriculture and

    of
    Rural Development Bank. The complaint was also filed in the name

    of the bank. Therefore, the name of the person on whose behalf the
    rt
    notice was issued was specifically mentioned, and the judgment of

    the Punjab and Haryana High Court in Mansa Central Co-operative

    Bank Ltd (supra) does not apply to the present case.

    40. The accused has not claimed that he had repaid the

    money after the service of the notice.

    41. Therefore, it was proved on record that the accused had

    issued a cheque in favour of the complainant to repay the debt,

    which cheque was dishonoured with an endorsement “insufficient

    funds” and the accused failed to repay the money despite the receipt

    of valid notice of demand. Therefore, all the ingredients of the

    commission of an offence punishable under Section 138 of the NI Act

    were duly satisfied, and the learned Trial Court had rightly convicted

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    the accused of the commission of an offence punishable under

    Section 138 of the NI Act.

    42. The learned Trial Court sentenced the accused to undergo

    .

    simple imprisonment for 2 months and pay a compensation of

    ₹1,00,000/-. It was laid down by the Hon’ble Supreme Court in Bir

    Singh v. Mukesh Kumar, (2019) 4 SCC 197: (2019) 2 SCC (Cri) 40: (2019)

    2 SCC (Civ) 309: 2019 SCC OnLine SC 138 that the penal provision of

    of
    section 138 is deterrent in nature. It was observed at page 203:

    rt
    “6. The object of Section 138 of the Negotiable Instruments
    Act is to infuse credibility into negotiable instruments,

    including cheques, and to encourage and promote the use of
    negotiable instruments, including cheques, in financial
    transactions. The penal provision of Section 138 of the
    Negotiable Instruments Act is intended to be a deterrent to

    callous issuance of negotiable instruments such as cheques
    without serious intention to honour the promise implicit in
    the issuance of the same.”

    43. Keeping in view the deterrent nature of the punishment,

    a sentence of one year cannot be said to be excessive.

    44. The accused had issued a cheque of ₹95,000/- and the

    learned Trial Court awarded a compensation of ₹ 1,00,000/- which

    means that the learned Trial Court had only awarded a

    compensation of ₹5,000/- to the complainant. It was laid down by

    the Hon’ble Supreme Court in Kalamani Tex v. P. Balasubramanian,

    (2021) 5 SCC 283: (2021) 3 SCC (Civ) 25: (2021) 2 SCC (Cri) 555: 2021

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    SCC OnLine SC 75 that the Courts should uniformly levy a fine up to

    twice the cheque amount along with simple interest at the rate of

    9% per annum. It was observed at page 291: –

    .

    19. As regards the claim of compensation raised on behalf of
    the respondent, we are conscious of the settled principles that
    the object of Chapter XVII of NIA is not only punitive but also

    compensatory and restitutive. The provisions of NIA envision
    a single window for criminal liability for the dishonour of a
    cheque as well as civil liability for the realisation of the cheque

    of
    amount. It is also well settled that there needs to be a
    consistent approach towards awarding compensation, and
    unless there exist special circumstances, the courts should
    uniformly levy fines up to twice the cheque amount along with
    rt
    simple interest @ 9% p.a. [R. Vijayan v. Baby, (2012) 1 SCC 260,
    para 20: (2012) 1 SCC (Civ) 79: (2012) 1 SCC (Cri) 520]”

    45. The complainant was deprived of the interest to which it

    would have been entitled, had it advanced the money to other

    persons. The complainant had to engage a counsel and to prosecute

    the complaint before the learned Trial Court, and it was entitled to

    be compensated for it. Considering all these circumstances, the

    compensation of ₹5,000/- is inadequate. However, the complainant

    failed to file any appeal for enhancement of the sentence and no

    interference is required with the amount of compensation awarded

    by the learned Trial Court.

    46. No other point was urged.

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    2026:HHC:31278

    47. In view of the above, there is no infirmity in the

    judgments and order passed by the learned Courts below. Hence, the

    present revision fails and is dismissed.

    .

    48. The present revision stands disposed of, and so are the

    pending miscellaneous application(s), if any.

    49. The record of the learned Courts below be returned with a

    of
    copy of the judgment.

    
                                                    (Rakesh Kainthla)
                        rt                             Judge
         29th July, 2026
           (Nikita)
    
    
    
    
    
    
    
    
    
                                                   ::: Downloaded on - 29/07/2026 20:33:24 :::CIS
     



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