Partly allowed¶¶25

Sandeep Bhatia v. Dilbag Singh

Punjab & Haryana HC1 Apr 2026CRR/241/2020

Case brief

AI extract

What is this about?

Sandeep Bhatia v. Dilbag Singh, CRR-241-2020, High Court of Punjab and Haryana at Chandigarh (Anoop Chitkara, J.), decision dated 01.04.2026. Section 138 NI Act cheque-dishonour conviction upheld; sentence of RI one year reduced to period already undergone (4 months 12 days per custody certificate); compensation of Rs. 6,01,560/- under Section 357(3) CrPC untouched, recovery governed in accordance with law; respondent ex parte despite service, legal aid counsel appointed vide order dated 30.03.2026; revision disposed of without merits adjudication.

What did the court decide?

Sentence reduced to the period already undergone (4 months and 12 days as per custody certificate); conviction upheld; petition disposed of with pending miscellaneous applications, if any, disposed of; legal aid counsel entitled to fee as per applicable Rules.

Sandeep Bhatia Vs Dilbag Singh — Cheque Dishonour | Punjab & Haryana HC (2026)

What the court decided

AI extract

Outcome

¶¶25

Issue for consideration

Whether the judgment of conviction and order of sentence dated 26.07.2017 passed by JMIC, Sirsa, as affirmed by the Additional Sessions Judge, Sirsa, should be set aside. +1 more

¶¶14

Court's answer

The order of sentence is modified to the extent that the period of sentence is reduced to the period already undergone by the petitioner, which is 4 months and 12 days as per custody certificate.

¶¶24

Ratio / Principle

The judgment of conviction is upheld, the Court expressing no further opinion on the merits.

¶¶24

Key takeaways

No specific order is passed with regard to recovery of compensation (Rs. 6,01,560/- awarded under Section 357(3) CrPC); the same shall be governed in accordance with law.ratio¶¶24
Considering that the cheque amount involved is around Rs. 6,00,000/-, which translates to Rs. 5,000/- per day of custody already undergone, the sentence undergone by the petitioner is more than adequate.ratio¶¶23

Detailed headnote1 paragraphs

Criminal Revision (CRR-241-2020, decided 01.04.2026, Anoop Chitkara, J.): Petitioner convicted under Section 138 NI Act by JMIC, Sirsa (RI for one year plus compensation of Rs. 6,01,560/- under Section 357(3) CrPC), affirmed by the Additional Sessions Judge, Sirsa. Revision not argued on merits; conviction upheld without expressing any opinion on merits. Considering the cheque amount of around Rs. 6,00,000/- (translating to Rs. 5,000/- per day of custody already undergone), sentence reduced to the period already undergone, i.e., 4 months and 12 days as per custody certificate. No specific order on recovery of compensation, which shall be governed in accordance with law. Petition disposed of; legal aid counsel entitled to fee as per applicable Rules.

¶1

¶2

CRR-241-2020

¶3

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH

¶4

211

¶5

CRR-241-2020 Date of Decision: 01.04.2026

¶6

SANDEEP BHATIA ......... Petitioner

¶7

Versus

¶8

DILBAG SINGH ......... Respondent

¶9

CORAM: HON'BLE MR. JUSTICE ANOOP CHITKARA

¶10

Present: Mr. Raj Kumar Bhatia, Advocate for the petitioner/convict. Ms. Shivaly Singla, Advocate legal aid counsel for the respondent/complainant.

¶11

¶12

ANOOP CHITKARA, J. (ORAL)

¶13

Criminal Case before trial Court	No. 18-2 of 2015 CIS No. 659/201 CNR No. HRSI0 Decided on: 26.0	5 3-009096-2015 7.2017
Criminal Appeal before Appellate Court	No. 275 CIS No. 275/201 CNR No. HRSI0 Decided on: 09.0	7 100-4604-2017 1.2020
Convict’s name	Penal provision	Sentence
Sandeep Bhatia	138 of NI Act	RI for 01 year and to pay compensation under Section 357(3) CrPC of amount equivalent to two cheques amount i.e. Rs. 6,01,560/-to complainant.

¶14

Seeking setting aside of impugned judgment of conviction and order of sentence dated 26.07.2017 passed by JMIC, Sirsa convicting the petitioner and affirmed by Additional Sessions Judge, Sirsa, the petitioner had come up before this Court by filing the present revision petition.

¶15

Despite service, the respondent failed to appear, therefore, vide order dated 30.03.2026, this Court appointed a legal aid counsel on his behalf.

¶16

At the outset, counsel for the petitioner submits that he would be contended and satisfied if the sentence is reduced to the period already undergone, which is approximately 04 months out of 01 year in the complaint captioned above and he does not want to argue the revision petition on merits. He further submits that the cheque amount was around

¶17

JYOTI 2026.04.07 16:38 I attest to the accuracy and integrity of this order/judgment.

¶18

CRR-241-2020 2

¶19

Rs. 6,00,000/- and the period already undergone would translate to Rs. 5000/- per day, which

¶20

is higher than the prevailing norm in the absence of the sentencing policy.

¶21

Legal aid counsel submits that it appears that nothing was paid and the sentence should not be reduced.

¶22

I have heard counsel for the petitioner as well as legal aid counsel for the respondent and its analysis would lead to the following outcome.

¶23

In the entirety of facts and circumstances and considering the cheque amount involved is around Rs. 6,00,000/- which would translate to Rs. 5000/- per day of custody already undergone, this Court is of the opinion that the sentence undergone by the petitioner is more than adequate.

¶24

Without commenting any further opinion on the merits, judgment of conviction is upheld and order of sentence is modified to the extent that the period of sentence is reduced to the period already undergone by the petitioner, which is 4 months and 12 days as per custody certificate. No specific order is being passed with regard to recovery of compensation and the same shall be governed in accordance with law.

¶25

With the aforesaid modification, petition stands disposed of. All pending miscellaneous applications, if any, stand disposed of.

¶26

Legal aid counsel shall be entitled to her fee as per the applicable Rules.

¶27

(ANOOP CHITKARA) JUDGE

¶28

01.04.2026 Jyoti-II

¶29

Whether speaking/reasoned Yes/No Whether Reportable Yes/No

¶30

JYOTI 2026.04.07 16:38 I attest to the accuracy and integrity of this order/judgment.

Sandeep Bhatia v. Dilbag Singh

Case brief

What is this about?

What did the court decide?

Sandeep Bhatia v. Dilbag Singh

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

Case details

Similar cases

Sahil Vs Inderpal Singh

Raj Kumar Vs Vijay Singh and Another

Sahab Singh Vs State of Haryana & Ors.

Debo Kaur Vs State of Punjab

M/S Jena Automatives Vs M/S Hfl Indutries and Another

M/S Jeena Automotives Vs M/S Hfl Industries and Another