This article is written by Aditya Anand, a student from Symbiosis Law School, Noida. In this article, the author has covered a brief about the Act and some special provisions have been discussed and analyzed thoroughly.
The Negotiable Instrument Act was promulgated in the year 1881 which was introduced to ease the growth of banking and commercial transactions. The basic purpose was to legalize the system of negotiable instruments. The Act was enforced during British rule and to date, most of the provisions still remain unchanged. The Ministry of Finance is the nodal organization that regulates the system related to negotiable instruments. The process of transfers from one person to another in dealings of monetary value in terms of legal documents is the negotiable instrument. The legal definition of negotiable is that something can be transferable from one party to another party by delivery so that the title shall pass with or without the endorsement to the transferee. After getting a better clarity of the concept, the other important aspects and the Act have been discussed in the content.
Objective of the Act
Before delving deeper into the “Negotiable Instrument Act”, let us see some of the basic concepts that would be required for a better understanding of the statute. Negotiable Instruments play an important role in financial transactions. A negotiable instrument is a signed written document. The purpose of this document is to transfer the specific amount of money to the assigned person.
The instrument bears the promise to pay the sum of money at an assigned future date or on-demand as the case may be. One of the common examples that we can see in our day-to-day life is a draft that is the specific amount of money payable by the payer or the personal check. There are no certain set of fixed conditions to consider a document as the negotiable instrument; however, for an instrument to be negotiable, it must be signed with a mark or signature, by the maker of the instrument that is the one who issues drafts. The person who promises the amount of money is known as the drawer of funds and the person receiving it is known as the drawee of funds.
Some of the essential characteristics provide a distinctive identity. These are:
- Movable- The negotiable instrument is a convenient method of transferring money that is easily and portable. There are no hectic and lengthy procedures as simple steps are needed for transferring the ownership of the instrument by simple delivery or by a valid endorsement.
- Written- The negotiable instrument transactions should be in the written form. The documentation works can be handwritten notes, printed, or typed.
- Definite time- The period for the order of payment must be certain. If the date is not specified then also it must be within a reasonable time. If the payment order depends upon convenience and choice then it cannot be considered as a negotiable instrument.
- Specified persons- Like the time,the payee must also be certain or determined. There can be more than one drawee in the negotiable instruments and the person may include artificial persons like company, any separate legal entity, or the authorized persons.
Most of the negotiable instruments transactions can be categorized into three parts. However, there are no explicit statements that it is limited or it must be specified into only three parts. The railway receipts or the delivery orders are also common examples of negotiable instruments.
- Promissory notes-This transaction generally takes place between the debtor and the creditor. The debtor creates the instrument promising the amount of money on a specified date.
- Bills of Exchange- This is just the opposite of the promissory notes as this is an order from the creditor to the debtor. Here, the creditor makes the instrument that instructs the debtor to pay the payee a certain amount of money. The bill is created by the creditor.
- Cheque- This is just one of the forms of bill of exchange. In this case, the drawee is a bank and such cheques are payable on demand. The bank is instructed by the debtor to pay a certain amount of money to the assigned payee.
Let us have a look at the purpose of the Negotiable Instrument Act.
- The Act aims to create the legal provisions for the negotiable instruments system that is currently in operation throughout the country. The regulatory laws would systematically organize the system and the Act would define a decisive authority to decide any issues relating to negotiable instruments.
- The Act defines every subject related to the negotiable instruments for better clarity and understanding. For example, who is the drawer, drawee, acceptor, etc are mentioned in the various sections.
- The Act provides the penal provisions for effective implementation of the negotiable instruments process among the parties. If any party breaches its obligation or there is nonfulfillment of the said duty then they may be charged with offenses leading to imprisonment.
- The Act protects the right of the parties when they discharge their obligations diligently.
- The Act mentions different conditions about the transaction systems and laid down its specific provisions.
- The Act eliminates all kinds of discrepancies or hurdles that may arise between the parties. In case of any dispute, the parties would have to undergo the established provisions, and such would legally resolve the matter.
- The Act regulates the different negotiable instruments like promissory notes, Bills of Exchanges, and cheques.
In order to regulate the negotiable instruments under the Act, it should fulfill some of the essential features that would be mandatorily fulfilled to consider the Negotiable instrument.
- Writing- Every negotiable instruments transaction would be in writing as the parties would have relevant documents of negotiable instruments. This may vary as per the rules depending upon the type of negotiable instruments such as promissory notes, bills of exchanges, cheques, etc. There is no scope of any verbal dealings among the parties as per the law and it would not be considered in case of any disputes. A written document serves as a prima facie document or evidence in a court of law explaining the factual matters in case of any disputes between the parties.
- Signature- The instrument has no value unless it gets validated by the parties. The sign acts as an authentication of the valid consent for the settlement transactions between the parties. Thus, instruments must be duly signed by the parties.
- Monetary value- The negotiable instruments should be exclusively dealt with in terms of money that are recognized by the government as well as the laws of the country. The transactions in legal tender money would be the sole intention to have this under the negotiable instruments. The products or any other transactions would be invalid and so it must be strictly in terms of monetary terms.
- Demand- Nowadays, “this system is very popular in business as well as other commercial transactions”. This is a safe and convenient mode of payment and settlement between the parties. There is no need for any cash as the amount would get directly transferred to the payee as per the rules of the banking transactions.
- Reliable System- The convenient mode of transactions and the efficient mode of the system both are simultaneously required for the development and growth. The safe system and the credibility of the banks would ensure that the money gets transferred easily and to the right people.
2002 Amendment to the Negotiable Instruments Act
The Negotiable Instrument Act has been amended on a timely basis to eliminate the discrepancies or any such hurdles that would reduce the efficiency of the Negotiable Instruments Act. There was the need of the hour when the system and people had widely accepted the exhaustive use of instruments for any business or personal transaction. The development of electronic data exchange and technology has limited the scope of the laws formulated earlier. Earlier, agriculture was a prime occupation, and most of the transactions were dealt in cash but after the diversity of occupation and services, the general public has explored the scope of banking transactions which resulted in heavy transactions of amounts through banks.
The Act was mainly formulated to create legislation regarding cheques, bills of exchanges, and promissory notes. The statute was passed to deal with the particular form of contract and to lay down special provisions. Since the negotiable instruments have been widely used in commercial and banking transactions over a long period of time as one of the best suited for transferring money. Some of the obsolete legislation has defeated the purpose of negotiable instruments.
The need for such amendments was to reduce the cases of dishonoring cheques by introducing penal provisions by the stringent implementation of laws. In the recent article of the Hindu, there are around 35 lakh cheque bounces till date that are pending before various courts mentioned by the Supreme Court recently. The increasing number of dishonoring cheques has stated the need for amendments to eliminate the loopholes. The amendments of 2002 have introduced new sections from Section 143 to Section 147 that has widened the scope and diminished the limitation of the parent Act. The introduction of five new sections and the Amendment Act was brought into force on Feb 6, 2002. The Sections come under Chapter XVII that was primarily for penal provisions as the person can be charged with offenses for dishonoring the cheques in case of deficiency of funds. If we observe the past then there was no timely disposal of cases as it would become burdensome since the procedure of court was time taking and inefficient. Some of the provisions are
Section 143 states the court authority to deal with the cases that would come under Judicial Magistrate of the first class or Metropolitan Magistrate and the provisions from Section 262 to Section 265 of Code of Criminal Procedure shall be applied as per the facts of the case. It further states that when the case is filed, the hearing should be done on a day-to-day basis until its final disposal of cases and in exceptional circumstances, the court shall state the reasons for not conducting a trial on the following day. The case filed under this Section should be disposed of within six months from the date of filing the complaint. This practice would be consistent with the interest of justice.
Section 144 of the NI Act defines the different modes of summoning. When the Magistrate issues summons to an accused, he may direct a copy of the summons at the place where the accused originally resides or carries business or personally works for the gain by the method of speed post or other courier services which can be authorized by the court of session. The same applies in the case of witnesses also. The acknowledgment of the receipt should be signed by the accused or witness in front of that person who has been assigned by the Postal department. If the accused or witness refuses to accept the delivery of the summons, then the court may implicitly consider that the summons has been duly received.
Section 145 defines the evidence on affidavit as the evidence of the complainant may be given by him on affidavit and it may be subject to all just exceptions that to be read in evidence in any inquiry, trial, or proceedings under the said code. The court, if finds such situations, t can summon any person giving evidence on the affidavit as to the facts.
Compounding of offenses under NI Act vs. CrPC
What are compounding offenses?
It must be sure that after reading the statement stated above a question would pop up in the mind what does it mean by compounding of offenses. In terms of law, compounding is a kind of settlement mechanism where the accused party agrees to pay a sum of money against the prosecution to avoid long and hectic litigation as well as criminal charges.
The key advantage is that the offender gets relieved from the trials as well as the charges and the complaint also gets a sum of money. In other words, this is an act where both the parties agree on the settlement process and the person filing the complaint shall not prosecute the accused in exchange for money thus resulting in the accused getting relieved from any kind of punishment.
Laws related to compounding of offenses
Now, let us understand the laws related to compounding. Section 147 of the Act deals with the compounding of offenses in which a complainant, in exchange for money or some other consideration, comes to a settlement as not to prosecute the accused. This Section was effective from the year 2003. There can be two types of offenses : minor and serious.
If there are serious offenses, then compounding of such offenses can only be undertaken by the complainant who files the suit and the validity of the compounding can only be upheld after the ratification and the permission of the court, whereas in case of minor offences the High Courts and Sessions Court can allow compounding of offence in accordance with Sections.
Earlier, the first amendment was passed in the year April 1, 1989, to reduce the cases of dishonor of cheques. The amendment introduced new sections from 138 to 142 in the Negotiable Instrument Act, 1881 to deal with the dishonor cheques. It mentioned the type of offenses and prosecution for dishonoring the cheques. It was brought as per Section 4 of the Banking Public Financial Institutions and Negotiable Instrument Laws(Amendment) Act, 1988. The objective of the Act was to prohibit the cases of dishonor of cheques and encourage the use and credibility of cheques.
Over the course of time, when certain deficiencies were identified in dealing with cases of dishonor of cheques, then again alterations were made to the NI Act that was effective from 6 February 2006. It is also discussed in detail in the above content in the 2002 Amendment. So, from this amendment, new sections from 143 to 147 were set in motion and it empowered the Magistrate to adopt a summary trial for expeditious disposal within 6 months. The Magistrate can also put a fine that can be double the amount mentioned in the cheque. Specifically, Section 147 allowed parties to compound the offense.
What is Section 147?
The Section defines the offenses to be compoundable “Notwithstanding anything contained in the Code of Criminal Procedure, 1973, (2 of 1974.) every offense punishable under this Act shall be compoundable.”
Section 147 of NI Act vs. Section 320 of CrPC
Before the introduction of Section 147, the provisions of Section 320 of CrPC were applied for the compounding of offenses. Section 320 of CrPC deals in various offenses punishable under IPC and in the case of an offense under Section 138 of NI Act, the legislature thought it fit to permit compounding without the leave of the court as generally dishonor of cheque arises out of commercial transactions between private parties. That’s why Section 147 starts with a non-obstante clause to keep it out of the purview of Section 320 of CrPC. Nowadays all the offenses are dealt with under Section 147 of the NI Act that is extensive and exclusive for these specific offenses.
Is compounding a right?
This might be a question as to whether any provision grants the parties the right of compounding of offenses. If we simply observe then only Section 147 is involved in the issues related to the compounding of offenses, but in the above-mentioned Section, it is nowhere stated that this is a right. If we look then, nowhere it is explicitly mentioned in the Section. So ultimately it creates a doubt whether compounding is a right granted to the accused or such right is subject to the consent of the complainant.
If it is not stated in the provisions of the Act, then let us see the judgment of the courts and how this dispute has been resolved. In the case of Ranjita Mittal & Ors. vs State Of Delhi & Anr. on 20 April (2012), the Delhi High Court stated that compounding is possible only when both the parties agree to it. This statement has not been explicitly mentioned but it can be derived. The matter was that the accused filed a petition under Section 482 of CrPC before the Delhi High Court for quashing the proceedings of the lower court which convicted him. The decision undertaken by the lower court was to reject the petitioner’s prayer for the compounding of the offense. The accused even agreed on the amount of the cheque on which the complaint has objection for compounding. The learned counsel of the respondent side stated to the court that they cannot be forced to accept the money that is mentioned in the cheque. The accused is liable to pay more money than the said amount on the cheque that is the fine. Further it was concluded that the complainant is not interested to enter into any kind of settlement and cannot be forced to do so.
The Delhi High Court further strengthened its argument by relying on Para 5 of judgment M/S Hitek Industries (Bihar) Ltd. … vs The State Of Delhi & Anr. (2010), of the Delhi High Court. Para 5 states that “the word compromise itself signifies an agreement between the two parties to compound the offense. If the parties do not agree to compound the offense, the court has to proceed with the complaint”.Therefore, the lower court decision was upheld and it was agreed that compromise is not valid unless it is agreed by both parties.
Judgments of Supreme Court
Undoubtedly, the judgments of the Apex Court give us better clarity of Section 147. The Hon’ble Supreme Court in the case of Damodar S.Prabhu vs Sayed Babalal H, (2010) stated that Section 147 does not carry any guidance as to how to proceed with the compounding of offenses, and further it was noticed that Section 320 of CrPC also cannot be applied. Therefore, the Apex Court exercised its power under Article 142 of the Constitution and laid down guidelines for encouraging compounding at the earliest stage.
Supreme Court Guidelines
The guidelines state the payment of costs should be made as per the laid downscale. This has been made with a pre-condition for allowing compounding of the offense.
In the circumstances, it is proposed as follows:
- Those 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 offenses 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.
- 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 deposit 10% of the cheque amount as a condition for compounding with the Legal Services Authority, or such authority as the court deems fit.
- 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.
- Finally, if the application for compounding is made before the Supreme Court, the figure would increase to 20% of the cheque amount.
It has been further clarified by the Hon’ble Supreme Court that the guidelines stated above are indicative and it is not obligatory to follow, as the discretion is vested in the court dealing with such disputes. It can be concluded that the courts will have to first analyze the facts of the case and resolve the matter and they can impose costs as per the case which will be deposited with the designated Legal services authority or any other authority as deemed fit.
The award of compensation
The complainant might feel how they are going to benefit from the settlement process so this question may arise: whether the objective of the said provisions is to punish the accused or recover the cheque amount in case of dishonour of cheques. This matter was discussed in detail by the Apex Court in the case of R. Vijayan vs Baby & Anr(2011). The Court stated this matter in Para no 15 which is discussed below:
Para 15 states that “The apparent intention is to ensure that not only the offender is punished, but also ensure that the complainant invariably receives the amount of the cheque by way of compensation under Section 357(1)(b) of the Code. Though a complaint under Section 138 of the Act is regarding criminal liability for the offense of dishonoring the cheque and not for the recovery of the cheque amount, (which strictly speaking, has to be enforced by a civil suit), in practice once the criminal complaint is lodged under Section 138 of the Act, a civil suit is seldom filed to recover the amount of the cheque. This is because of the provision enabling the court to levy a fine linked to the cheque amount and the usual direction in such cases is for payment as compensation, the cheque amount, as loss incurred by the complainant on account of dishonor of cheque, under Section 357(1)(b) of the Code and the provision for compounding the offences under Section 138 of the Act. Most of the cases (except those where liability is denied) get compounded at one stage or the other by payment of the cheque amount with or without interest. Even where the offence is not compounded, the courts tend to direct payment of compensation equal to the cheque amount (or even something more towards interest) by levying a fine commensurate with the cheque amount. A stage has reached when most of the complainants, in particular, the financing institutions (particularly private financiers) view the proceedings under Section 138 of the Act, as a proceeding for the recovery of the cheque amount, the punishment of the drawer of the cheque for the offence of dishonour, becoming secondary.”
As the provisions of Chapter XVII of the Act strongly lean towards grant of reimbursement of the loss by way of compensation, the courts shall uniformly exercise the power, unless there are special circumstances, in all cases of conviction, to levy fines up to twice the cheque amount and direct payment of such amount as compensation. The order of the court directing to pay compensation by way of restitution concerning the loss on account of dishonour of the cheque should be reasonable and as per the guidelines and the amount not only limited to the payment of the cheque amount but interest thereon at a reasonable rate. Thus, It is advisable to the complainant that it enters into a compromise dictating his terms with the accused and files such compromise in the court for compounding of the offence.
Code for trial under Sections 143-147
The Special Leave Petition (Criminal) No. 5464 of 2016 order of the Supreme Court has stated the general code of trial in case of dishonour of cheques. The order passed was related to the dishonour of two cheques on 27 January 2015 for the amount of Rupees one lakh and seventy thousand only. The dispute had been on trial for more than sixteen years. After observing the delay in disposal of cases, the Chief Justice of India and other judges examined thoroughly. The Registry of Supreme Court registered a Suo Motu Writ Petition (criminal) named as “Expeditious trial of cases under Section 138 of the Negotiable Instrument Act, 1881”. Mr. Siddharth Luthra was appointed as Amicus Curiae or friend of the court as he was a learned Senior Counsel.
The rules for the trial of cases relating to dishonors have already been stated between Section 143 and Section 147. In the year 1989, Chapter XVII was inserted in the Act that contained sections from 138 to 142 where the dishonor of cheques was made punishable with imprisonment or fine or with both. The defence would also be not available to the prosecution as stated in Section 140.
Section 143 was introduced after the 2002 amendment act that gave the authority to the court to conduct a trial under Section 138 of the Act. Section 143(3) states that the court would try its best to dispose of the case within six months from the date after filing of the complaint. The method of service for the summoning of cases has been dealt with under Section 144 of the Act.
Section 145 states that the evidence of complaint that is given by the person on affidavit can be accepted as evidence in any inquiry, trial, or proceedings under the code. The bank slip or memo in which it would be written that the cheque is dishonored would be considered evidence at first view that is mentioned in Section 146. The person can be charged with a compoundable offence punishable under Section 147 for one or two years.
Despite the necessary amendments, the situation of the code of conduct has still not improved the situation as there are too many pending cases of the complaint filed under Section 138 of the Act. As per the preliminary report submitted on 31 December 2019 by learned Amicus Curiae Advocate Siddharth Luthra, it was shown that there are about 2.31 crores pending cases out of which about 35.16 Lakh cases are related to Section 138 of the Act. There has been a major difference between the rate of complaints and the rate of disposal of cases. The reason stated for such delay in disposal of cases is that the rate of filing complaints is much greater than the rate of disposals.
The basic foundation of the trial that can be conducted lies in Section 138 of the Negotiable Instrument Act. In simple words, Section 138 describes the dishonour of cheques for insufficiency of funds in the account. When a cheque is issued in the name of a person by the person of the account holder, from which cheque will be withdrawn for any amount and if the cheque doesn’t get cashed due to insufficient funds then the person or the issuing authority or account holder that is commonly known as drawer will be held liable for offence. The person may be punished with imprisonment for a maximum term of two years or with the fine of twice the amount stated in the cheque, or with both as the case may be.
Certain conditions are mandatorily followed such as the cheque must be presented within six months from the date on which it is issued or the period of validity. Another condition is the payee or the holder in due course of the cheque, as the case may be, makes a demand for the payment of the said amount of money by giving a notice in writing, to the drawer of the cheque within thirty days of the receipt of information by him from the bank regarding the return of the cheque as unpaid and the drawer of such cheque fails to make the payment of the said amount of money to the payee or, as the case may be, to the holder in due course of the cheque, within fifteen days of the receipt of the said notice.
The objectives of these provisions have been implemented for speedy disposal of cases as Section 143(2) allows the Magistrate to convert the summary trials to summons. If he feels that a sentence of imprisonment is exceeding one year then he may start the summons trial. Thus, the speedy disposal of cases would be possible through such provisions.
Section 482 CrPC as a substitute
Section 482 describes the special powers of the High Courts. This Section discusses inherent powers given to the court which empowers them to pass such orders when there is the abuse of the process of trial in the lower court or to give effect to such an order under this code. The prime objective is to prevent the miscarriage of justice or violation of any rights. The objective of the criminal laws is to punish the wrongdoers and to protect society from the lawbreakers. The Section has its relevance of power over the compoundable offences as well as non-compoundable offences. When there is a delay in disposal of cases unreasonably or a long period unnecessarily then the High court can interfere in the matter. This section is limited to certain conditions that have to be mandatorily fulfilled to use this power.
The relevance of this Section related to the issues pertaining to the NI Act can better be understood from the case of Tathagat Exports (P) Ltd. v. PEC Ltd, (2020). The Delhi High Court dismissed the petition filed against the order of Session Court. It was a review petition that was filed by the petitioners for turning down the orders of the metropolitan magistrate relating to matters involved under Section 138 and Section 141 of the Negotiable Instruments Act,1881 that was against the petitioners.
The issue involved here is that there is a respondent company that filed suit against the petitioners in respect of non-payment of money against the four dishonoured cheques. The cheques amounting to Rs 16 crores were issued in favour of the respondent company by the petitioner’s company. The complaint was filed under Section 138 with Section 142 of the NI Act. The Metropolitan magistrate strictly took this matter into cognizance and passed orders of summoning to the accused. The aggrieved accused took this matter to the High Court.
The petitioners contended that the demand notice that was served was defective as the amount mentioned was more than the amount of the cheque. It was further claimed that the notice was vague and ambiguous.
The High Court rejected the points contended by the petitioners and it was held that notice should be thoroughly read. After doing the drill-down analysis of the notice, it explicitly stated that the details of the cheques state that it was dishonored so no other way it can be said that the demand was confusing. In addition, the petitioners never denied that cheques were not issued or dishonored due to insufficiency of funds. Now, the question arose whether the petitioners who already availed the remedy under the provisions of the NI Act can file the revision suit under Section 482 CrPC as a substitute for initiating a second revision petition which is barred under Section 397(3) of the CrPC. The section describes that if a person files the application under this section in the Session Judge or the High Court Judge then, no further application by the same person shall be entertained by the other of them.
As per the facts and the rules, the High Court stated that there are already mentioned provisions from Sections 142 to Section 147 under Chapter 17 of the NI Act. The special code for the trial of offences has also been briefly discussed under the said provisions. In the present case, the court didn’t find any reasonable grounds to maintain the suit under Section 482 CrPC. Further, the defence given by the petitioners requires valid ground of evidence to get appreciated, evaluated, and adjudged in the proceedings under Section 482.
Therefore, the petitioner’s suit was not maintainable as there was no violation of any rights or miscarriage of justice. There was no error in the process of law as well and so the petition was dismissed.
The pandemic effect
The COVID 19 has brought the world to a standstill with such a disastrous situation that adversely affected the lives of humans. The initial order by the Apex Court was issued on 17 July 2020 taking cognizance of the matter of dishonoring of cheques under Section 138 of the Negotiable Instruments Act, 1881. The Hon’ble Supreme Court has permitted different kinds of modes for serving the notices such as email, fax, and other types of instant messaging services. The demand notice through the mode of the email was always a question as to whether it could be acceptable in the court of law as per the rule mentioned in Section 138 of the Act, as the traditional method of filing the criminal complaint by the legal profession through hard copy process was always a convenient method. Thus, the process of serving the notices and other procedures is to be done through an electronic medium. However, the intent of the lawmakers was not to restrict the services of demand notices only to physical modes.
There has been no alteration or any kind of concession in the rules of presentation of cheque or demand draft. This was also reflected in the Supreme Court decision where the court dismissed the writ petition Harsh Nitin Gokhale vs Reserve Bank of India (2020) filed under Article 32 of the Constitution by the petitioner Harsh Nitin Gokhle for seeking relief to exclude the time period of lockdown for calculating the limitation for the presentation of cheque/demand draft as directed by the Reserve Bank of India vide Notification dated 04.11.2011. The Court stated that they can’t issue any such orders in contravention to the notification issued by the RBI. Therefore, the petition was dismissed.
The Act is a cornerstone in economic and finance-related matters. It is the beacon light for all the persons who would face any kind of wrongs related to financial dealings if it is mentioned in the Act. It is of no doubt, after getting a few aspects of the provisions, that the law of the country is highly stringent towards any kind of discrepancies or any voluntary wrong committed by the people. The Act was also amended from time to time to mitigate the financial cases. The Act also helps in the development of the ease of doing business as there would be a reduction in case of any disputes among the parties and it can be resolved through the legislation and some other process. Some special provisions that were added after the amendment are a boon for diligent persons.
- https://taxguru.in/corporate-law/compounding-offence-negotiable-instruments-act-1881.html#:~:text=New%20Sections%20143%20to%20147were,parties%20to%20compound%20the%20 offense
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