Disposed¶9

Jyoti v. Ravinder Singh

Punjab & Haryana HC2 Sept 2025CRM-A/163/2023

Case brief

AI extract

What is this about?

Leave to appeal; Section 378(4) CrPC; Section 372 proviso; victim; Section 2(wa) CrPC; Section 138 NI Act; acquittal; appeal by complainant; Section 413 BNSS 2023; Celestium Financial; conversion of Section 378(4) application into Section 372 appeal; Sessions Judge; SDJM Bholath; Punjab & Haryana High Court; 2025.

What did the court decide?

Application disposed of with direction to the concerned Sessions Judge to treat it as filed under Section 372 CrPC and assign it to the Court concerned for decision; Registry directed to send the complete paper-book and trial Court record, if received, along with the said order forthwith, informing the parties. ¶9

Jyoti Vs Ravinder Singh — Cheque Dishonour | Punjab & Haryana HC (2025)

What the court decided

AI extract

Outcome

¶9

Issue for consideration

Whether the application under Section 378(4) CrPC for leave to appeal against the acquittal in a Section 138 NI Act complaint should be dealt with as an appeal under the proviso to Section 372 CrPC, the complainant being a 'victim' per the Supreme Court's ruling in Celestium Financial.

¶9

Court's answer

In view of the Supreme Court's holding in M/s Celestium Financial vs. A. Gnanasekaran Etc. (complainant under Section 138 NI Act treated as a 'victim' entitled to appeal under the proviso to Section 372 CrPC, corresponding Section 413 BNSS 2023), the present application is disposed of by directing the concerned Sessions Judge to treat it as having been filed under Section 372 CrPC and assigning it to the Court concerned for decision.

¶9

Detailed headnote1 paragraphs

Punjab & Haryana High Court (Aman Chaudhary, J., oral order dated 02.09.2025) — Criminal miscellaneous application under Section 378(4) CrPC by Jyoti seeking leave to appeal against the judgment of acquittal dated 14.11.2022 passed by the Sub Divisional Judicial Magistrate, Bholath, in a complaint under Section 138 NI Act against Ravinder Singh. Relying on the Supreme Court's ruling in M/s Celestium Financial vs. A. Gnanasekaran Etc., 2025 SCC OnLine 1320 — that a complainant in a Section 138 NI Act complaint is a 'victim' under Section 2(wa) CrPC and an appeal lies under the proviso to Section 372 CrPC (corresponding Section 413 BNSS 2023) against such acquittal — the Court disposed of the application, directing the concerned Sessions Judge to treat it as filed under Section 372 CrPC and assign it to the Court concerned for decision; Registry to forward the paper-book and trial Court record forthwith and inform the parties.

Jyoti v. Ravinder Singh

Case brief

What is this about?

What did the court decide?

Jyoti v. Ravinder Singh

Case brief

What is this about?

What did the court decide?

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What the court decided

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