Dismissed¶¶47

Leo Infracapital Limited v. Radlay Metal Products Private Limited & Ors.

Delhi HC10 Dec 2025CRL.REV.P.(NI)/51/2025

Case brief

AI extract

What is this about?

Section 138 Negotiable Instruments Act 1881; NI Act cheque dishonour conviction; criminal revision petition CRL.REV.P.(NI) 45/2025 to 51/2025; High Court of Delhi; Sanjeev Narula; Additional Sessions Judge South District Saket Courts; common judgment 15 May 2023; acquittal of director Vimmi Kakkar; conviction upheld of Radlay Metal Products Pvt Ltd and Naresh Kumar; 545 days delay in filing revision petition; gross unexplained delay; compensation amount already paid to complainant including cheque amount and interest; fine deemed imposed on company and Accused No. 2; revision petitions dismissed for delay and lack of merit.

What did the court decide?

The 545-day delay in filing the revision petitions was gross and, in the opinion of the Court, had not been satisfactorily explained. ¶¶47

Leo Infracapital Limited Vs Radlay Metal Products Private… — Cheque Dishonour | Delhi HC (2025)

What the court decided

AI extract

Outcome

Dismissed

¶¶47

Issue for consideration

Whether the seven revision petitions challenging the Appellate Court's common judgment (which partly allowed the accused's appeals under Section 138 NI Act by acquitting Accused No. 3) should be entertained, given that they were filed after a delay of 545 days from the impugned order and the compensation amount has already been paid to the complainant.

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Court's answer

The 545-day delay in filing the revision petitions was gross and, in the opinion of the Court, had not been satisfactorily explained.

¶¶47

Ratio / Principle

The compensation amount as per the order of sentence stands paid to the complainant by Accused No. 1 company and Naresh Kumar; thus the Petitioner has already received the compensation amount, which includes the cheque amount and also interest thereon.

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Key takeaways

Coupled with the inordinate and unexplained delay, the Court found no ground to entertain the petitions, both on the ground of inordinate and unexplained delay as well as their being devoid of merits.ratio¶¶47

Detailed headnote1 paragraphs

Delhi High Court (Sanjeev Narula, J; order dated 10.12.2025) dismissed seven criminal revision petitions (CRL.REV.P.(NI) 45/2025 to 51/2025, with connected CRL.M.As) filed by Leo Infracapital Limited and Leo Ispat Limited against a common judgment dated 15th May, 2023 of the Additional Sessions Judge, South District, Saket Courts, New Delhi. The appellate judgment had partly allowed the accused's appeals under Section 138 of the Negotiable Instruments Act, 1881 by acquitting Director Accused No. 3 (Vimmi Kakkar), while upholding the convictions of Accused No. 1 (Radlay Metal Products Pvt. Ltd.) and Accused No. 2 (Naresh Kumar), and modifying the order on sentence so that no independent liability existed on Vimmi Kakkar and the fine was deemed imposed on the company and Naresh Kumar. The revision petitions, filed after a delay of 545 days that the Court found gross and not satisfactorily explained, were dismissed because the compensation amount per the order of sentence — including the cheque amount and interest thereon — had already been paid to the complainant by Accused No. 1 company and Naresh Kumar; the Court found no ground to entertain the petitions both on account of the inordinate and unexplained delay and as devoid of merits.

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$~59 to 65

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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- CRL.REV.P.(NI) 45/2025, CRL.M.A. 5442/2025 & CRL.M.A. 5443/2025

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LEO INFRACAPITAL LIMITED .....Petitioner Through: Mr. Avadh Bihari Kaushik, Mr. Prateek Goyal, Mr. Risabh Kumar & Ms. Saloni Mahajan, Advs.

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versus

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RADLAY METAL PRODUCTS PRIVATE LIMITED & ORS. .....Respondents

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Through: Mr. Mohit Chaudhary, Mr. Kunal Sachdeva and Ms. Katyani Vajpayee, Advs.

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60 + CRL.REV.P.(NI) 46/2025, CRL.M.A. 5446/2025 & CRL.M.A. 5447/2025 LEO ISPAT LIMITED .....Petitioner Through: Mr. Avadh Bihari Kaushik, Mr. Prateek Goyal, Mr. Risabh Kumar & Ms. Saloni Mahajan, Advs.

¶9

versus

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RADLAY METAL PRODUCTS PRIVATE LIMITED & ORS. .....Respondents

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CRL.REV.P.(NI) 45/2025 and other connected matters Page

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1 of 5

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This is a digitally signed order.

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The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 12/12/2025 at 12:43:24

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Through: Mr. Mohit Chaudhary, Mr. Kunal Sachdeva and Ms. Katyani Vajpayee, Advs.

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CRL.REV.P.(NI) 47/2025, CRL.M.A. 5449/2025 & CRL.M.A. 5450/2025 LEO INFRACAPITAL LIMITED .....Petitioner Through: Mr. Avadh Bihari Kaushik, Mr. Prateek Goyal, Mr. Risabh Kumar & Ms. Saloni Mahajan, Advs.

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versus

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RADLAY METAL PRODUCTS PRIVATE LIMITED & ORS. .....Respondents

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Through: Mr. Mohit Chaudhary, Mr. Kunal Sachdeva and Ms. Katyani Vajpayee, Advs. 62 + CRL.REV.P.(NI) 48/2025, CRL.M.A. 5453/2025 & CRL.M.A. 5454/2025

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LEO INFRACAPITAL LIMITED .....Petitioner Through: Mr. Avadh Bihari Kaushik, Mr. Prateek Goyal, Mr. Risabh Kumar & Ms. Saloni Mahajan, Advs.

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versus

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RADLAY METAL PRODUCTS PRIVATE LIMITED & ORS. .....Respondents Through: Mr. Mohit Chaudhary, Mr. Kunal Sachdeva and Ms. Katyani Vajpayee, Advs. 63

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CRL.REV.P.(NI) 45/2025 and other connected matters Page 2 of 5

¶25

This is a digitally signed order.

¶26

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 12/12/2025 at 12:43:24

¶27

CRL.REV.P.(NI) 49/2025, CRL.M.A. 5456/2025 & CRL.M.A. 5457/2025 LEO ISPAT LIMITED ..... Petitioner Through: Mr. Avadh Bihari Kaushik, Mr. Prateek Goyal, Mr. Risabh Kumar & Ms. Saloni Mahajan, Advs.

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versus RADLAY METAL PRODUCTS PRIVATE LIMITED & ORS. .....Respondents Through: Mr. Mohit Chaudhary, Mr. Kunal Sachdeva and Ms. Katyani Vajpayee, Advs. 64 + CRL.REV.P.(NI) 50/2025, CRL.M.A. 5459/2025 & CRL.M.A. 5460/2025 LEO ISPAT LIMITED ..... Petitioner Through: Mr. Avadh Bihari Kaushik, Mr. Prateek Goyal, Mr. Risabh Kumar & Ms. Saloni Mahajan, Advs. versus RADLAY METAL PRODUCTS PRIVATE LIMITED & ORS. .....Respondents Through: Mr. Mohit Chaudhary, Mr. Kunal Sachdeva and Ms. Katyani Vajpayee, Advs. 65 + CRL.REV.P.(NI) 51/2025

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CRL.REV.P.(NI) 45/2025 and other connected matters Page 3 of 5

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This is a digitally signed order.

¶31

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 12/12/2025 at 12:43:24

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LEO INFRACAPITAL LIMITED ..... Petitioner

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Through: Mr. Avadh Bihari Kaushik, Mr. Prateek Goyal, Mr. Risabh Kumar & Ms. Saloni Mahajan, Advs.

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versus

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RADLAY METAL PRODUCTS PRIVATE LIMITED & ORS.

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.....Respondents Through: Mr. Mohit Chaudhary, Mr. Kunal Sachdeva and Ms. Katyani Vajpayee, Advs.

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CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA

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O R D E R % 10.12.2025

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The present set of revision petitions are directed against a common judgment dated 15^th May, 2023, passed by the Additional Sessions Judge, South District, Saket Courts, New Delhi, in seven criminal appeals preferred by the accused.

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By the impugned order, the Appellate Court, while deciding the appeals filed by the accused challenging their conviction and sentence under Section 138 of the Negotiable Instruments Act, 1881¹ , partly allowed the same by acquitting one of the Directors, Accused No. 3 (Vimmi Kakkar). The conviction of Accused No. 1 (Radlay Metal Products Pvt. Ltd.) and Accused No. 2 (Naresh Kumar) was upheld. Consequently, in view of the acquittal of Accused No. 3, the order on sentence was modified to clarify that no independent liability would exist on Vimmi Kakkar, and the fine

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1 “NI Act”

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CRL.REV.P.(NI) 45/2025 and other connected matters Page 4 of 5

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This is a digitally signed order.

¶44

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 12/12/2025 at 12:43:24

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amount would be deemed to have been imposed on Accused No. 1 company and Accused No. 2.

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It is pertinent to note that the present revision petitions have been filed after a delay of 545 days from the impugned order.

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Notwithstanding this gross delay, which, in the opinion of the Court, has not been satisfactorily explained, it is pertinent to note that the compensation amount as per order of sentence stands paid to the complainant by Accused No. 1 company and Naresh Kumar. Thus, the Petitioner has already received the compensation amount which includes the cheque amount and also interest thereon. In view of the foregoing, coupled with the inordinate and unexplained delay in filing these revision petitions, this Court finds no ground to entertain the petitions both on the ground of inordinate and unexplained delay as well as being devoid of merits. 5. Accordingly, the present revision petitions are dismissed.

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SANJEEV NARULA, J

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DECEMBER 10, 2025/ ng

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CRL.REV.P.(NI) 45/2025 and other connected matters Page 5 of 5

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This is a digitally signed order.

¶52

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 12/12/2025 at 12:43:24

Leo Infracapital Limited v. Radlay Metal Products Private Limited & Ors.

Case brief

What is this about?

What did the court decide?

Leo Infracapital Limited v. Radlay Metal Products Private Limited & Ors.

Case brief

What is this about?

What did the court decide?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

Case details

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