Issues: (i) Whether a cash loan transaction allegedly violating Section 269SS affects the statutory presumptions and enforceability of liability under the cheque-dishonour provisions; (ii) Whether remand for fresh consideration was justified where execution of the cheques was admitted and the trial court had not properly assessed the evidence relevant to rebuttal of the presumptions.

Issue (i): Whether a cash loan transaction allegedly violating Section 269SS affects the statutory presumptions and enforceability of liability under the cheque-dishonour provisions.

Analysis: Admission of execution of a cheque raises the presumption of consideration and the presumption that the holder received it towards a legally enforceable debt or liability. A breach of Section 269SS attracts the stipulated penalty under Section 271D, but neither provision declares the underlying transaction illegal, invalid, or void. Such breach therefore does not, by itself, make the debt unenforceable or dislodge the statutory presumptions.

Conclusion: A cash transaction exceeding the prescribed limit does not by itself render the debt unenforceable or rebut the presumptions under the Negotiable Instruments Act; the issue is against the accused-appellant.

Issue (ii): Whether remand for fresh consideration was justified where execution of the cheques was admitted and the trial court had not properly assessed the evidence relevant to rebuttal of the presumptions.

Analysis: The presumption in favour of the holder is rebuttable, but a bare denial is insufficient. The drawer must furnish an explanation, supported by cogent material, regarding the issuance of the cheque and its possession by the payee. Proof that the payee lacked financial capacity may assist rebuttal. The record indicated that evidence regarding the complainant's capacity to lend had been adduced but was not properly evaluated. As the challenged order was a remand order, appreciation of the evidence on merits was inappropriate.

Conclusion: The remand for a fresh decision after proper consideration of the evidence was justified; the issue is against the accused-appellant.

Final Conclusion: The trial court must expeditiously reconsider the complaint in accordance with the applicable presumptions and the evidentiary burden of rebuttal.

Ratio Decidendi: Violation of a fiscal restriction on cash loans, where it attracts only a statutory penalty and does not invalidate the transaction, cannot by itself defeat the presumptions of consideration and legally enforceable liability arising from an admitted cheque.

Issues: (i) Whether the temporary injunction ought to be modified to permit sale of the appellant's existing stock packed in red cartons through third-party distributors, franchisees, or retailers; (ii) Whether the empty cartons bearing the impugned trade dress were liable to be destroyed and restrained from further use.

Issue (i): Whether the temporary injunction ought to be modified to permit sale of the appellant's existing stock packed in red cartons through third-party distributors, franchisees, or retailers.

Analysis: The stock already in the hands of distributors, franchisees, and retailers was no longer in the appellant's custody or control. The Court also noted that there had been no production after the injunction order and that the last invoice and manufacture dates preceded the relevant restraint. On that basis, the existing stock could be marketed if packed in a package that was not red in colour or otherwise similar to the respondent's packaging.

Conclusion: The injunction was modified to permit sale of the existing stock through third parties in the manner indicated, in favour of the appellant.

Issue (ii): Whether the empty cartons bearing the impugned trade dress were liable to be destroyed and restrained from further use.

Analysis: The empty cartons were found to carry the disputed trade dress and were capable of continued misuse. To preserve the effect of the temporary restraint, their destruction was directed and their utilisation was prohibited.

Conclusion: The empty cartons were ordered to be destroyed and not used, against the appellant.

Final Conclusion: The interim injunction was varied only to the limited extent of permitting disposal of the existing third-party stock, while the restraint on the impugned empty cartons continued.

Issues: Whether the appellant was entitled to regular bail in a prosecution under the Indian Penal Code, 1860 and the Unlawful Activities (Prevention) Act, 1967, having regard to the period of custody, the stage of trial, and parity with co-accused.

Analysis: The appellant had remained in custody since 20.10.2021. The witnesses whose safety required protection had substantially been examined, while the remaining protected witnesses were stated to relate mainly to the role attributed to co-accused. Some co-accused had already been enlarged on bail. The Court considered the length of incarceration, the likelihood of further delay in conclusion of the trial, and the plea of parity, while making it clear that no opinion was being expressed on the gravity of the alleged offence.

Conclusion: The appellant was granted regular bail, subject to furnishing bail bonds and complying with the conditions imposed by the NIA Court, including weekly presence before the jurisdictional police station and cooperation with the trial.

Issues: Whether the appellant, who had remained in custody for more than one year and against whom the charge sheet and supplementary charge sheet had been filed, was entitled to bail pending trial.

Analysis: The Court noted the length of incarceration and the fact that investigation had substantially progressed with filing of the charge sheet and supplementary charge sheet. In these circumstances, the Court found that further custodial detention of the appellant was not required. The order also records that no opinion was being expressed on the merits of the prosecution case and that the grant of bail was for the limited purpose of release pending trial.

Conclusion: The appellant was held entitled to release on bail on such terms and conditions as the trial court may impose.

Issues: Whether the criminal complaint and the summoning order were liable to be quashed on the ground that the dispute was essentially civil in nature and the criminal process was being used to recover money.

Analysis: The dispute arose out of commercial supply transactions and the record showed that the parties had earlier pursued cheque-bounce proceedings which ended in a monetary settlement. The material relied upon to suggest criminal liability was limited, and the alleged email acknowledging liability was neither produced before the Court nor sufficient to connect the later complaint with any antecedent act of cheating. The company had already been ordered to be wound up before the alleged acknowledgment, so the director could not validly bind the company in the manner suggested. On these facts, the complaint appeared to be an attempt to convert a failed civil recovery into criminal prosecution, a course the Court found impermissible.

Conclusion: The quashing petition ought to have been allowed and the criminal proceedings could not be sustained.

Final Conclusion: The impugned order was set aside and the criminal case was quashed as against the appellants.

Ratio Decidendi: Criminal process cannot be permitted to continue where the materials disclose a commercial dispute being pursued as a means of debt recovery without a sustainable basis for alleging criminality.

Outcome: The Special Leave Petition stood dismissed and the pending application(s), if any, stood disposed of.

Issues: Whether a writ petition can be disposed of by declining to entertain it on the ground of an efficacious alternative remedy while still granting interim protection to the petitioner; and whether such a course is permissible under Article 226 of the Constitution of India.

Analysis: The order reiterates that once the High Court, after applying its mind, refuses to entertain a writ petition because an efficacious alternative remedy is available and has not been pursued, the writ proceeding comes to an end. In that situation, no final relief survives for grant in the writ petition. Interim protection by way of stay of the impugned order or maintenance of status quo cannot be granted merely to facilitate recourse to the alternate forum, because such relief is only ancillary to substantive relief on merits. The order treats this position as controlled by the settled principle that interim relief cannot be used as the only and final relief under Article 226.

Conclusion: Such interim protection is impermissible when the writ petition itself is not entertained on the ground of availability of an efficacious alternative remedy, and the writ proceedings must terminate upon that refusal.

Final Conclusion: The special leave petition was not entertained, and the judgment affirms the limited reach of Article 226 where the High Court declines writ jurisdiction in favour of an alternative statutory remedy.

Ratio Decidendi: Interim relief cannot be granted as the sole or final relief under Article 226 after the Court declines to entertain the writ petition for availability of an efficacious alternative remedy; such relief must be merely ancillary to substantive adjudication.

Issues: Whether anticipatory bail should be granted when the accused has joined the investigation and custodial interrogation is not shown to be necessary, and whether cooperation with investigation can compel self-incrimination.

Analysis: The appellant had joined the investigation and was cooperating. The only grievance raised was non-production of the mobile phone, but cooperation with investigation does not extend to requiring an accused to incriminate himself. In the absence of grounds warranting custodial interrogation, continued protection from arrest was justified, subject to compliance with lawful conditions.

Conclusion: Anticipatory bail was granted and the denial of relief by the High Court was set aside.

Final Conclusion: The appellant obtained pre-arrest protection, with liberty to proceed on bail in the event of arrest, subject to compliance with the stipulated statutory conditions.

Ratio Decidendi: Where an accused has joined the investigation and custodial interrogation is not necessary, anticipatory bail may be granted, and cooperation with investigation cannot be equated with compelled self-incrimination.

Issues: Whether interim bail should be granted to the petitioner in the pending criminal proceedings arising out of the alleged liquor scam, having regard to the stage and complexity of the investigation and the competing claims of liberty and effective investigation.

Analysis: The proceedings involved a large-scale alleged scam, multiple accused persons, several charge-sheets or prosecution complaints already filed, further investigation still pending, and a substantial number of witnesses proposed to be examined. The Court balanced the petitioner's claim to liberty and prolonged custody against the prosecution's need for an uninterrupted and effective investigation, and considered that the investigation was likely to take considerable time. To ensure that the investigation was not impeded while protecting personal liberty, the Court granted interim bail with stringent conditions, including restrictions on travel, residence, appearance, contact with witnesses, and public statements on the allegations.

Conclusion: Interim bail was granted to the petitioner in both matters, subject to the stated conditions.

Ratio Decidendi: In complex multi-accused criminal investigations expected to continue for a considerable time, interim bail may be granted by balancing the accused's right to liberty against the prosecution's need for an unhindered investigation, and by imposing conditions sufficient to prevent interference with the process.

Outcome: Arguments heard. Judgment reserved. Written submissions may be filed within one week.

Issues: Whether the appellant was entitled to bail on parity with co-accused, and whether continued incarceration was warranted after completion of investigation and filing of charge-sheet.

Analysis: The allegations against the appellant were found to be substantially similar to those against the co-accused, with only a marginally higher allegation relating to receipt and use of proceeds of crime. The alleged use of those proceeds was treated as a matter to be examined at trial. Since investigation had been completed and charge-sheets had been filed, further incarceration was not considered justified.

Conclusion: The appellant was held entitled to be released on bail.

Issues: (i) Whether the special leave petition became infructuous on account of the petitioner's acquittal by the Trial Court; (ii) whether prolonged custody and delay in commencement or conclusion of trial justified bail; (iii) whether bail should be granted subject to conditions in view of the volume of prosecution evidence and anticipated delay.

Issue (i): Whether the special leave petition became infructuous on account of the petitioner's acquittal by the Trial Court.

Analysis: The petitioner's acquittal by the Trial Court eliminated the live controversy in the matter. Once the underlying criminal case no longer survived against the petitioner, no adjudication on merits remained necessary.

Conclusion: The petition became infructuous and stood disposed of as such.

Issue (ii): Whether prolonged custody and delay in commencement or conclusion of trial justified bail.

Analysis: The petitioner had remained in custody since October 2022, the trial had not formally commenced, the charge-framing stage was still continuing, and the prosecution case involved examination of a very large number of witnesses. The delay was treated as sufficiently inordinate to justify consideration of release on bail, though the matter was kept pending for further hearing to explore a special-court arrangement.

Conclusion: The prayer was not finally decided on that date and the matter was posted for further hearing.

Issue (iii): Whether bail should be granted subject to conditions in view of the volume of prosecution evidence and anticipated delay.

Analysis: The petitioner had spent a long period in custody, had no criminal antecedents, and the trial was likely to take a considerable time. The Court considered that release on bail could be ordered if suitable safeguards were imposed to ensure attendance, prevent delay, and avoid contact with witnesses or associates.

Conclusion: Bail was granted subject to stringent conditions and liberty to seek cancellation upon breach.

Final Conclusion: The common order disposed of one petition as infructuous, kept one matter pending for further hearing, and granted conditional bail in the other matter.

Outcome: The Special Leave Petition was dismissed, and the time granted by the High Court for hearing of the appeal was extended by six weeks.

Issues: Whether the criminal proceedings under Section 138 of the Negotiable Instruments Act, 1881 deserved to be quashed in view of the settlement reached between the parties through mediation.

Analysis: The settlement agreement dated 18.08.2025 was taken on record and the parties were directed to abide by its terms. In view of the settlement, the continuation of the criminal proceedings was no longer warranted.

Conclusion: The impugned order was set aside and the criminal proceedings arising out of S.T.C.No.62/2021 were quashed.

Issues: Whether the cost imposed on the accused, payable to the Legal Services Authority pursuant to the settlement based on the earlier decision, was legally sustainable.

Analysis: The appellant had been convicted under Section 138 of the Negotiable Instruments Act, 1881, but the matter was later settled between the parties during the revisional stage and the appellant was acquitted subject to deposit of costs. The challenge before the Court was confined to the direction requiring payment of costs to the Legal Services Authority. The Court held that the earlier decision relied upon could not be treated as a binding precedent in the sense of laying down an inflexible mandate applicable to every case, particularly where the complainant had no objection and the appellant was unable to comply.

Conclusion: The direction imposing costs on the appellant could not be sustained and was set aside.

Ratio Decidendi: A settlement-based cost direction, though referable to Article 142 of the Constitution of India, does not operate as an inflexible binding precedent in every case, and such costs cannot be mechanically sustained where the facts do not justify their continuance.

Outcome: The appeal was disposed of by requesting the High Court to decide the pending revision expeditiously and by directing continuation of the interim order till disposal of the revision petition.