Sribasta Lanchhan Barik v. Smitarani Parida
Case brief
What is this about?
Keywords: CRLMC No.179 of 2026; High Court of Orissa at Cuttack; Dr. Justice Sanjeeb K Panigrahi; Sribasta Lanchhan Barik v. Smitarani Parida; Criminal Revision No.10/06 of 2025; 1CC No.332 of 2019; S.D.J.M. Rourkela; JMFC Rourkela; Section 145(1) and Section 145(2) NT Act of 1881 / Negotiable Instrument Act; affidavit in lieu of examination-in-chief; complainant-only affidavit evidence; accused cannot tender affidavit evidence; dismissal - no ground to interfere. Relevant to searches on whether an accused in an NI Act (cheque/dishonour) proceeding may submit affidavit-mode evidence instead of examination-in-chief.
What did the court decide?
This Court found no ground whatsoever to interfere with the impugned order dated 27.11.2025 passed by the 2nd Additional District and Sessions Judge in Criminal Revision No.10/06 of 2025, and accordingly dismissed the CRLMC. (The High Court itself issued no independent ruling on Sections 145(1)/(2); the S.145 analysis reproduced in the judgment is that of the court below.)