Thursday, 2 May 2024

When the court should not allow amendment of date mentioned in complaint and evidence recorded under S 138 of NI Act?

 Presently, an application has been filed seeking

amendment of the date of the cheque from 22.07.2010 to

22.07.2012 as also changing the date in the evidence

recorded by the complainant to the same effect. It is in

that light, at the first instance, the learned Magistrate

considering the application has rightly concluded that

even if the amendment/ correction is permitted in the

complaint to indicate the date as 22.07.2012, the

evidence supporting the case of the appellant contains

the year as 2010, and as such, the amendment/ correction

would not be justified. {Para 6}

9. In a matter of the present nature, where the date

is a relevant aspect based on which the entire aspect

relating to the issue of notice within the time frame as

provided under the Negotiable Instruments Act, 1881, and

also as to whether as on the date there was sufficient

balance in the account of the issuer of the cheque would

be the question, the amendment, as sought for, in the

present circumstance, was not justified.

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL No. OF 2024

MUNISH KUMAR GUPTA  Vs M/S MITTAL TRADING COMPANY.

Dated: 30th April, 2024.


1. Leave granted.

2. Heard the learned counsel for the appellant and

perused the appeal papers.

3. The respondent, though served, has not chosen to

appear and have his say in the instant proceedings.

4. From a perusal of the record, it is noted that the

respondent had initiated a complaint under Section 138 of

the Negotiable Instruments Act, 1881 read with Section

420 of the Indian Penal Code, 1860. In the complaint, it

has been alleged that the appellant, to discharge its

financial liability, had issued an account payee cheque

dated 22.07.2010 bearing No.732966. The complaint had

been filed on 02.01.2013. The matter has thus proceeded

before the learned Magistrate. Subsequently, the

respondent had tendered evidence before the learned Trial

Court. At that stage, claiming that inadvertently a

typographical error had arisen with regard to mentioning

the year of the cheque, the respondent had filed an

application seeking amendment of the said complaint. The

application for amendment was filed as late as on

24.10.2017. The learned Magistrate, having taken note of

the said application for amendment, has through her Order

dated 13.07.2018, arrived at the conclusion that the

amendment, as sought for, would not be justified inasmuch

as the said date, which is now sought to be corrected,

has already been recorded in the evidence during crossexamination

and also the relevant documents contain the

same. The respondent, claiming to be aggrieved by the

said order dated 13.07.2018, went before the High Court

assailing the same. The High Court, through its judgment

and order dated 04.01.2023, has allowed the said

application and permitted the respondent to carry out the

amendment. It is in that circumstance, the accused in the

said case is before us assailing the judgment/ order of

the High Court.

5. Having heard the learned counsel for the appellant,

a perusal of the documents before us would indicate that

from the very stage of issue of notice demanding

payment, the date of the cheque had been indicated as

22.07.2010. Subsequent thereto, in the complaint as also

while tendering the evidence, the date was recorded as

22.07.2010.

6. Presently, an application has been filed seeking

amendment of the date of the cheque from 22.07.2010 to

22.07.2012 as also changing the date in the evidence

recorded by the complainant to the same effect. It is in

that light, at the first instance, the learned Magistrate

considering the application has rightly concluded that

even if the amendment/ correction is permitted in the

complaint to indicate the date as 22.07.2012, the

evidence supporting the case of the appellant contains

the year as 2010, and as such, the amendment/ correction

would not be justified.

7. As against such conclusion reached by the learned

Magistrate, the High Court based on the discussion and

applying the principles laid down in the various

judgments cited therein by the learned counsel, allowed

the said application to carry out necessary corrections/

amendment. However, while ultimately arriving at the

conclusion as to whether the amendment is required to be

permitted, the High Court had merely arrived at the

conclusion that if such amendment is not permitted, it

would prove fatal to the case of the complainant and as

indicated, the respondent/complainant was only seeking

the correction of the year. The High Court has, in fact,

lost sight of the fact that the documents also contain

the said date and the evidence recorded is also to the

same effect.


8. Therefore, the opinion reached by the High Court

to arrive at the conclusion that the mistake could be

committed while taking copies from the computer would not

be justified in the facts of the present case where the

legal notice had indicated the date, and based on the

same, the complaint had been initiated.

9. In a matter of the present nature, where the date

is a relevant aspect based on which the entire aspect

relating to the issue of notice within the time frame as

provided under the Negotiable Instruments Act, 1881, and

also as to whether as on the date there was sufficient

balance in the account of the issuer of the cheque would

be the question, the amendment, as sought for, in the

present circumstance, was not justified.

10. Accordingly, the judgment and order dated

04.01.2023 passed by the High Court of Punjab and Haryana

at Chandigarh is set aside.

11. The appeal is, accordingly, allowed.

12. Pending application(s), if any, shall stand

disposed of.

...................J.

(A.S. BOPANNA)

...................J.

(SANJAY KUMAR)

New Delhi

30th April, 2024


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