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Supreme Court of India 2019-09-05 partly_allowed

Vani Agro Enterprises vs State of Gujarat and Ors

Bench: 2 — Deepak Gupta

In Brief

Four cheques issued by the appellant bounced. A single notice was sent under Section 138 of the Negotiable Instruments Act in 1999, but four separate complaints resulted, pending for 20 years. The appellant sought consolidation into a single trial, arguing that Section 219 of the Code of Criminal Procedure mandates joint trial of offences within one year. The Supreme Court held that while Section 219 permits joint trial, it does not require consolidation into one trial (maximum three cases per trial). No consolidation provision exists in law. The Court directed all four cases be heard on the same date for convenience, with the trial court retaining discretion on how evidence is recorded, and ordered disposal by 31 December 2019."

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Criminal Procedure Negotiable Instruments Act Cheque Bouncing Consolidation of Cases Judicial Delay

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