In Brief
In this group of criminal appeals, appellants convicted under Section 138 of the Negotiable Instruments Act for cheque dishonour challenged orders directing them to deposit 25% of imposed fines as a condition for suspension of sentence pending appeal. The Supreme Court held that amended Section 148 of the N.I. Act (introduced in 2018) applies to all pending cheque dishonour appeals, including those initiated before the amendment, as it is procedural and does not strip vested rights. Although Section 148 uses 'may', purposive interpretation reads it as 'shall'—effectively mandatory—reflecting Parliament's intent to curb delay tactics and protect cheque sanctity. The express override clause defeats reliance on Code of Criminal Procedure Section 357(2). Appeals were dismissed; appellants given four weeks to deposit the amounts.
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