Certified copy of a Punjab and Haryana High Court, Chandigarh judgment (digitally attested 'VISHNU 2025.01.20'); the copy is severely OCR-corrupted — title block, parties, advocates, coram, case number and the operative paragraphs are largely illegible. Legible fragments show a petition invoking a Cr.P.C. provision stated as 'now Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS)' (¶15). The judgment's core material is Section 202 Cr.P.C., throughout described as 'now Section 225 of BNSS': as amended (effective 23.06.2006, vide Act 25 of 2005, per quoted SC material) it obliges a Magistrate, where the accused resides beyond his jurisdiction, to postpone the issue of process and either inquire himself or direct an investigation to decide whether there is sufficient ground for proceeding; the full provision text is reproduced (¶¶35–46). The dispute context appears to be a cheque-dishonour complaint ('payment stopped by the drawer', ¶20). The court draws on Dainik Bhaskar Vs. M/s Satya Kesari and another (¶15, discussed through ¶32) and reproduces Supreme Court passages: (i) a judgment arising out of SLP (Crl) No. 9318 of 2012 (¶¶52–58) — a pure legal issue (non-compliance with Section 202 before issue of process) can be raised at any stage (citing National Textile Corpn. Ltd. v. Nareshkumar Badrikumar Jagad, (2011) 12 SCC 695, and the National Bank of Oman judgment); that appeal was allowed, quashing a notice dated 24.11.2009 with direction to the Magistrate to proceed afresh after following Section 202 procedure; (ii) a further SC judgment (name/citation illegible, cited at ¶60) recording High Courts' divergence on applying Section 202 to Section 138 complaints (¶61), whose para 24 conclusions are set out (¶¶69–83): practice directions on recording reasons for converting Section 138 summary trials; deemed service of summons across related Section 138 complaints; no inherent power to review/recall summons (Adalat Prasad and Subramanium Sethuraman upheld); Section 258 inapplicable to Section 138 complaints (Meters and Instruments disapproved); recommended amendment for multiple Section 138 offences within 12 months notwithstanding Section 219; Section 322 power preserved. No monetary amount is stated; the final disposition of this petition is not legible.
