In Brief
The appellant, a former director of a company, was prosecuted under the Negotiable Instruments Act for dishonored cheques issued during his directorship. His first application to quash the case was dismissed. He filed a second application with documentary proof (Form 32) that he had resigned before the cheques were issued. The High Court dismissed it on grounds of res judicata. The Supreme Court held that a successive application under Section 482 CrPC is maintainable when material facts change between applications. The Court found the resignation documents were not previously considered and constituted a material change warranting reconsideration. The proceedings were quashed, affirming that criminal liability cannot attach to a former director for acts committed after resignation.
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