S.P.Maharajan vs M.Masilamani on 21 July, 2026

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    Madras High Court

    S.P.Maharajan vs M.Masilamani on 21 July, 2026

                                                                                    CRL RC No. 932 of 2025
    
    
                                      IN THE HIGH COURT OF JUDICATURE AT MADRAS
                                                            DATED: 21-07-2026
                                                                  CORAM
                                         THE HON'BLE MR.JUSTICE SHAMIM AHMED
                                                           CRL RC No. 932 of 2025
                     S.P.Maharajan
                     S/o.Pandiyaraj,
                     Shifa Leather and Salt Merchant,
                     No.19, Trust Square Street,
                     Ayanavaram, Chennai - 600 023.
                                                                                         ..Petitioner(s)
                                                                    Vs
                     M.Masilamani
                     S/o.Muthukaruppan,
                     No.16/27, Vadivudaiamman Street,
                     Lakshmiamman Nagar,
                     Erukkancherry,
                     Kodungaiyur Post,
                     Chennai - 600 118.
                                                                                       ..Respondent(s)
    
                              Criminal Revision Petition is filed under Section 438 r/w 442 of BNSS,
                    2023 to set aside the order passed by the Hon’ble XV Additional District Judge,
                    City Civil Court at Chennai dated 13.03.2025 in C.A.No.114/2024 and
                    confirming the conviction and sentence passed by the trial court Metropolitan
                    Magistrate, Fas Track Court No.1 at Allikulam Egmore, Chennai in
                    STC.No.5616/2022 on 23.01.2024 for the offence punishable under sec.138 of
                    the N.I.Act accused is sentenced to one year simple imprisonment and pass such
                    further orders.
    
                                      For Petitioner(s):          Mr. K.M.Balaji
    
                                      For Respondent(s):          Mr.R.Rajesh
    
    
    
    
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                                                                                    CRL RC No. 932 of 2025
    
    
                                                           ORDER
    

    Heard Mr.K.M.Balaji, learned counsel appearing for the Petitioner and

    Mr.R.Rajesh, learned counsel for the Respondent.

    SPONSORED

    2. This Criminal Revision Petition has been filed by the petitioner to set

    aside the order passed by the Hon’ble XV Additional District Judge, City Civil

    Court at Chennai dated 13.03.2025 in C.A.No.114/2024 and confirming the

    conviction and sentence passed by the trial court Metropolitan Magistrate, Fas

    Track Court No.1 at Allikulam Egmore, Chennai in STC.No.5616/2022 on

    23.01.2024 for the offence punishable under sec.138 of the N.I.Act accused is

    sentenced to one year simple imprisonment.

    3. The facts of the case in a nutshell, led to filing of this Criminal

    Revision Petition and necessary for disposal of the same, are as follows:-

    a) The Petitioner was convicted and sentenced for the offence under

    Section 138 of the Negotiable Instruments Act, by the Metropolitan Magistrate

    made in STC. No.5616 of 2022 by the judgment dated 23.01.2024, to undergo

    simple imprisonment for one year with fine of double the cheque amount as

    contemplated under Section 138 of NI Act in default of payment of the said

    amount, to undergo further period of simple imprisonment for three months.

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    Aggrieved by the order of the Trial Court, the Petitioner filed a Criminal Appeal

    in C.A.No.114 of 2024 before the learned XV-Additional District and Sessions

    Judge, City Civil Court, Chennai.

    b) The learned XV-Additional District and Sessions Judge, City Civil

    Court, Chennai confirming the judgment passed by the Metropolitan Magistrate

    in STC. No.5616 of 2022 dated 23.01.2024, dismissed the said Appeal vide

    order dated 13.03.2025. Aggrieved by the same, the present Criminal Revision

    Petition has been filed.

    4. Today, when the matter is being taken up, the petitioner viz.,

    S.P.Maharajan and the respondent viz., M.Masilamani, have entered into a

    Memorandum of Compromise dated 26.02.2026, which is taken on record and

    as per the terms of the Compromise, the following conditions were laid down

    between the parties which are quoted as under:

    “3. The petitioner submit that during the pendency of criminal
    revision pending before this Hon’ble Court, the petitioner approached
    the respondent for compromise as out of Court settlement and the
    same has been agreed by the respondent and agreed for the cheque
    amount of Rs.2,00,000/- as per the settlement. The petitioner a sum of
    Rs.1,20,000/- settled by way of DD No.130202 dated 07.04.2025 and
    the original deposit receipt No.05605 dated 12.04.2024 for a sum of
    Rs.80,000/- to the respondent on 07.04.2025. The petitioner has no

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    CRL RC No. 932 of 2025

    objection taking the deposit amount Rs.80,000/- to the credit of FTC-1
    Metropolitan Magistrate Allikulam, Egmore, Chennai-8. ‘’

    5. Learned counsel for the Revision Petitioner submits that both the

    parties, who have entered into a Joint Memorandum of Compromise dated

    26.02.2026, are present before this Court, to the effect that the Criminal

    Revision case shall be settled in accordance with the terms and conditions as

    contained therein.

    6. Learned Counsel for the Revision Petitioner prays this Court that, the

    has entered into a Joint Memorandum of Compromise with the respondent on

    26.02.2026, the Revision Petitioner may be released from jail without imposing

    any condition.

    7. The learned counsel for the Respondent, submits that the entire amount

    has been deposited by the Revision Petitioner and no amount is due against the

    Revision Petitioner. He further submits that the Respondent is not interested in

    continuing the case against the Revision Petitioner and has no objection if the

    Petitioner is released from jail

    8. Learned counsel for the Revision Petitioner further submits that the

    present Revision has been filed on 02.06.2026 before this Court and on the basis

    of change in circumstances, as the parties have entered into Memorandum of

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    Compromise, it was prayed to this Court to compound the offence. It was

    further argued by the learned counsel for the Revision Petitioner that this Court

    has inherent powers to compound the offence, so that, ends of justice could be

    secured as the object of Negotiable Instruments Act is primarily compensatory

    and not punitive and moreover Section 147 of NI Act would have an overriding

    effect on Section 359 Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS).

    Irrespective of which stage, the parties are compromising with the kind leave of

    this Hon’ble Court.

    9. In support of his arguments, learned counsel for the Revision Petitioner

    has submitted that in the case of Damodar S. Prabhu vs. Sayed Babalal H

    reported at 2010 (2) SCC (Cri) 1328, the Hon’ble Apex Court had formulated

    the guidelines for compounding the offence under section 138 N.I. Act wherein

    in para 21, it was pleased to observe as under :

    “With regard to the progression of litigation in cheque
    bouncing cases, the learned Attorney General has urged this
    Court to frame guidelines for a graded scheme of imposing costs
    on parties who unduly delay compounding of the offence. It was
    submitted that the requirement of deposit of the costs will act as a
    deterrent for delayed composition, since at present, free and easy
    compounding of offences at any stage, however belated, gives an
    incentive to the drawer of the cheque to delay settling the cases for
    years. An application for compounding made after several years
    not only results in the system being burdened but the complainant

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    is also deprived of effective justice. In view of this submission, we
    direct that the following guidelines be followed:- THE
    GUIDELINES (i) In the circumstances, it is proposed as follows:

    (a) That directions can be given that the Writ of Summons
    be suitably modified making it clear to the accused that he could
    make an application for compounding of the offences at the first
    or second hearing of the case and that if such an application is
    made, compounding may be allowed by the court without
    imposing any costs on the accused.

    (b) If the accused does not make an application for
    compounding as aforesaid, then if an application for
    compounding is made before the Magistrate at a subsequent stage,
    compounding can be allowed subject to the condition that the
    accused will be required to pay 10% of the cheque amount to be
    deposited as a condition for compounding with the Legal Services
    Authority, or such authority as the Court deems fit.

    (c) Similarly, if the application for compounding is made
    before the Sessions Court or a High Court in revision or appeal,
    such compounding may be allowed on the condition that the
    accused pays 15% of the cheque amount by way of costs. (d)
    Finally, if the application for compounding is made before the
    Supreme Court, the figure would increase to 20% of the cheque
    amount.”

    10. Learned counsel for the Revision petitioner also submitted that in the

    case of M/s Meters and Instruments Private Limited and another vs. Kanchan

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    Mehta reported at 2017 (7) Supreme 558, the Hon’ble the Apex Court in para

    18, was pleased to observe as under :

    “i) Offence under Section 138 of the Act is primarily a civil
    wrong. Burden of proof is on accused in view presumption under
    Section 139 but the standard of such proof is “preponderance of
    probabilities”. The same has to be normally tried summarily as
    per provisions of summary trial under the Cr.P.C. but with such
    variation as may be appropriate to proceedings under Chapter
    XVII of the Act
    . Thus read, principle of Section 258 Cr.P.C. will
    apply and the Court can close the proceedings and discharge the
    accused on satisfaction that the cheque amount with assessed
    costs and interest is paid and if there is no reason to proceed with
    the punitive aspect.

    (ii)The object of the provision being primarily
    compensatory, punitive element being mainly with the object of
    enforcing the compensatory element, compounding at the initial
    stage has to be encouraged but is not debarred at later stage
    subject to appropriate compensation as may be found acceptable
    to the parties or the Court.

    (iii)Though compounding requires consent of both
    parties, even in absence of such consent, the Court, in the interests
    of justice, on being satisfied that the complainant has been duly
    compensated, can in its discretion close the proceedings and
    discharge the accused.

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    (iv)Procedure for trial of cases under Chapter XVII
    of the Act
    has normally to be summary. The discretion of the
    Magistrate under second proviso to Section 143, to hold that it
    was undesirable to try the case summarily as sentence of more
    than one year may have to be passed, is to be exercised after
    considering the further fact that apart from the sentence of
    imprisonment, the Court has jurisdiction under Section 357(3)
    Cr.P.C. to award suitable compensation with default sentence
    under Section 64 IPC and with further powers of recovery under
    Section 431 Cr.P.C. With this approach, prison sentence of more
    than one year may not be required in all cases. (v) Since evidence
    of the complaint can be given on affidavit, subject to the Court
    summoning the person giving affidavit and examining him and the
    bank’s slip being prima facie evidence of the dishonor of cheque, it
    is unnecessary for the Magistrate to record any further
    preliminary evidence. Such affidavit evidence can be read as
    evidence at all stages of trial or other proceedings. The manner of
    examination of the person giving affidavit can be as per Section
    264
    Cr.P.C. The scheme is to follow summary procedure except
    where exercise of power under second proviso to Section 143
    becomes necessary, where sentence of one year may have to be
    awarded and compensation under Section 357(3) is considered
    inadequate, having regard to the amount of the cheque, the
    financial capacity and the conduct of the accused or any other
    circumstances’.

    11. Learned counsel for the Revision Petitioner further relied upon the

    judgment of Gujarat High Court in the case of Kripal Singh Pratap Singh Ori

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    vs. Salvinder Kaur Hardip Singh reported in 2004 Crl. L. J. 3786 wherein, the

    Gujarat High Court was pleased to observe as under:-

    “31. In the circumstances, it is hereby declared that the
    compromise arrived between the parties to this litigation out of court
    is accepted as genuine and the order of conviction and sentence
    passed by the learned JMFC, Vadodara and confirmed in appeal by
    the learned Sessions Judge, Fast Track Court, Vadodara, therefore,
    on the given set of facts are hereby quashed and set aside as this court
    intends, otherwise to secure the ends of justice as provided under
    section 482 Cr.P.C. Obviously the order disposing Revision
    Application would not have any enforceable effect.”

    12. Learned counsel for the Revision Petitioner has also relied upon the

    judgment of Hon’ble the Apex Court in the case of Vinay Devanna Nayak vs.

    Ryot Seva Sahkari Bank Limited reported in AIR 2008 SC 716, wherein the

    Hon’ble Apex Court was pleased to observe as under :

    “18. Taking into consideration even the said provision
    (Section 147) and the primary object underlying Section 138, in
    our judgment, there is no reason to refuse compromise between the
    parties. We, therefore, dispose of the appeal on the basis of the
    settlement arrived at between the appellant and the respondent. 19.
    For the foregoing reasons the appeal deserves to be allowed and is
    accordingly allowed by holding that since the matter has been
    compromised between the parties and the amount of Rs.45,000/-
    has been paid by the appellant towards full and final settlement to
    the respondent-bank towards its dues, the appellant is entitled to

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    acquittal. The order of conviction and sentence recorded by all
    courts is set aside and he is acquitted of the charge levelled against
    him.”

    13. Learned counsel for the Revision Petitioner has argued that the law

    regarding compounding of offences under the N.I. Act is very clear and is no

    more res integra and the offences under the N.I. Act can be compounded even at

    any stage of the proceedings. He submits that in terms of the aforesaid law laid

    down by the Hon’ble Supreme Court, the parties may be permitted to compound

    the offence and the conviction of the petitioner be set aside.

    14. Learned Counsel for the Revision Petitioner further submits that this

    Court has already decided a similar issue vide judgment and order dated

    19.09.2025 in Crl.R.C.(MD)No.875 of 2025 [K.Balachenniappan Vs

    Jeyakrishnan]. The counsel argues that the present revision petitioner’s case is

    fully covered by the aforesaid judgment and prays that the present Revision

    Petition may be disposed of in the same terms. A copy of the judgment has been

    placed before the Court for perusal.

    15. I have heard the learned counsel for the Revision Petitioner, learned

    counsel for the Respondent and perused the materials placed on record.

    16. Considering the facts as narrated above, the following question arose

    for consideration.

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    ‘Whether the order passed by the Appellate Court confirming
    the conviction of the trial court under section 138 of Negotiable
    Instruments Act can be nullified by the High Court on the basis of
    compromise entered between the parties’.

    17. Before answering the aforesaid question as framed, I shall examine

    the relevant provision of the B.N.S.S, as well as the Negotiable Instrument Act.

    I may extract Section 359 of B.N.S.S., and Section 147 of Negotiable

    Instruments Act.

    Section 359 B.N.S.S. – Compounding of Offences –

    1) The offences punishable under the sections of
    the Bharatiya Nyaya Sanhita, 2023 specified in the first two
    columns of the Table next following may be compounded by the
    persons mentioned in the third column of that Table: –

    2)The offences punishable under the sections of the
    Bharatiya Nyaya Sanhita, 2023 specified in the first two
    columns of the Table next following may, with the permission
    of the Court before which any prosecution for such offence is
    pending, be compounded by the persons mentioned in the third
    column of that Table:–

    3) When an offence is compoundable under this
    section, the abetment of such offence or an attempt to commit
    such offence (when such attempt is itself an offence) or where
    the accused is liable under subsection (5) of section 3 or
    section 190 of the Bharatiya Nyaya Sanhita, 2023 (45 of 2023),
    may be compounded in like manner.

    (4)(a) When the person who would otherwise be

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    competent to compound an offence under this section is a child
    or of unsound mind, any person competent to contract on his
    behalf may, with the permission of the Court, compound such
    offence;

    (b) When the person who would otherwise be
    competent to compound an offence under this section is dead,
    the legal representative, as defined in the Code of Civil
    Procedure
    , 1908 (5 of 1908) of such person may, with the
    consent of the Court, compound such offence.

    (5) When the accused has been committed for trial
    or when he has been convicted and an appeal is pending, no
    composition for the offence shall be allowed without the leave
    of the Court to which he is committed, or, as the case may be,
    before which the appeal is to be heard.

    (6) A High Court or Court of Session acting in the
    exercise of its powers of revision under section 442 may allow
    any person to compound any offence which such person is
    competent to compound under this section.

    (7) No offence shall be compounded if the accused
    is, by reason of a previous conviction, liable either to enhanced
    punishment or to a punishment of a different kind for such
    offence.

    (8) The composition of an offence under this
    section shall have the effect of an acquittal of the accused with
    whom the offence has been compounded.

    (9) No offence shall be compounded except as
    provided by this section.

    Section 147 of the Negotiable Instrument Act:-

    Offences to be compoundable.—Notwithstanding anything

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    contained in the Code of Criminal Procedure, 1973 (2 of 1974),
    every offence punishable under this Act shall be compoundable.

    18. It is well settled that inherent power of the Court can be exercised

    only when no other remedy is available to the litigants and nor a specific

    remedy as provided by the statute. It is also well settled that if an effective,

    alternative remedy is available, the High Court will not exercise its inherent

    power, especially when the Revision Petitioner may not have availed of that

    remedy. The power can be exercised by the High Court to secure the ends of

    justice, prevent abuse of the process of any court and to make such orders as

    may be necessary to give effect to any order under this Sanhita or Act,

    depending upon the facts of the given case. This Court can always take note of

    any miscarriage of justice and prevent the same by exercising its power. These

    powers are neither limited, nor curtailed by any other provision of the Sanhita or

    Act. However, such inherent powers are to be exercised sparingly and with

    caution.

    19. In the instant case, it is true that the appeal was dismissed and the

    conviction and sentence was upheld by the appellate court, but it cannot be lost

    sight of the fact that this Court has power to intervene in exercise of its power

    only with a view to do the substantial justice or to avoid a miscarriage and the

    spirit of compromise arrived at between the parties. This is perfectly justified

    and legal too.

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    20. I have considered the judgments cited by the learned counsel for the

    Revision Petitioner as well as by the learned Counsel for the respondent and

    other decisions of the Hon’ble Apex Court and I do not think it necessary to

    enlist those decisions which are taken into consideration for the purpose of the

    present proceedings.

    21. In the instant case, the Revision Petitioner is invoking the inherent

    power of this court after dismissal of the appeal confirming his conviction and

    sentence. In these circumstances, I have to examine as to whether for

    entertaining the aforesaid case, any special circumstances are made out or not,

    so it can be legitimately argued and inferred and held that in all cases where the

    Revision Petitioner is able to satisfy this Court that there are special

    circumstances which can be clearly spelt out subsequent proceeding invoking

    inherent power of this court can be modified and cannot be thrown away on that

    technical argument as to its sustainability once the contesting parties entered

    into subsequent compromise.

    22. In view of the decisions rendered in the judgment dated 19.09.2025 in

    Crl.R.C.(MD)No.875 of 2025 [K.Balachenniappan Vs Jeyakrishnan] and

    taking into account the fact that the parties have settled the dispute amicably by

    way of compromise, this Court is of the view that the compounding of the

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    offence as required to be permitted.

    23. Accordingly, the present Criminal Revision Case is allowed in terms

    of Memorandum of Compromise arrived at between the parties to this litigation

    out of Court. The impugned judgment passed by the Hon’ble XV Additional

    District Judge, City Civil Court at Chennai dated 13.03.2025 in

    C.A.No.114/2024 and confirming the conviction and sentence passed by the

    trial court Metropolitan Magistrate, Fas Track Court No.1 at Allikulam Egmore,

    Chennai in STC.No.5616/2022 on 23.01.2024 is modified. The conviction and

    sentence under Section 138 of the Negotiable Instruments Act in STC. No.5616

    of 2022 dated 23.01.2024 stands anulled as this Court intends, otherwise to

    secure the ends of justice. The Revision Petitioner shall be treated as acquitted

    on account of compounding of the offence with the complainant/person

    affected.

    24. In the result,

    ● The Criminal Revision Case is allowed of in terms of Joint
    Memorandum of Compromise dated 26.02.2026.

    ● The impugned conviction and sentence passed by the Hon’ble XV
    Additional District Judge, City Civil Court at Chennai dated 13.03.2025 in
    C.A.No.114/2024 and confirming the conviction and sentence passed by the
    trial court Metropolitan Magistrate, Fas Track Court No.1 at Allikulam Egmore,
    Chennai in STC.No.5616/2022 on 23.01.2024 are hereby modified.

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    ● The conviction and sentence imposed on the Revision Petitioner by
    both the courts below stands anulled.

    ● The Revision Petitioner shall be treated as acquitted on account of
    compounding of the offence with the complainant/respondent. Consequently,
    connected miscellaneous petition is closed.

    21-07-2026
    rli

    To

    1. The XV Additional District Judge,
    City Civil Court at Chennai.

    2. The Metropolitan Magistrate,
    Fas Track Court No.1
    Allikulam Egmore, Chennai

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    SHAMIM AHMED, J.

    rli

    CRL RC No. 932 of 2025

    21-07-2026

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