Concurrent sentencing in cheque dishonour cases depends on a single transaction rule; default sentences remain outside concurrency.

Section 427 CrPC permits a court to direct concurrent running of later sentences, but the discretion must be exercised on the facts of the transactions. In cheque dishonour complaints, concurrency is generally justified where multiple complaints arise from the same loan or financial arrangement and the cheques are linked to one transaction. Where complaints arise from separate and distinct borrowing transactions, concurrent running is not warranted and the sentences run consecutively. The concurrence direction applies only to substantive sentences and does not extend to default sentences imposed in lieu of fine or compensation.

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Issues: Whether the substantive sentences imposed in multiple cheque dishonour complaints arising out of different loan transactions could be directed to run concurrently under Section 427 of the Code of Criminal Procedure, 1973, and whether such concurrence could extend to default sentences.

Analysis: Section 427 of the Code of Criminal Procedure, 1973 embodies a general rule that a subsequent sentence runs consecutively to the earlier sentence unless the court directs concurrency. The power to order concurrent running is discretionary and must be exercised judicially having regard to the nature of the offences and the facts constituting the transactions. The governing principle is the single transaction rule: where several complaints arise from the same loan or financial arrangement and the dishonoured cheques are linked to that common transaction, concurrency is normally justified. However, where the complaints arise from separate and distinct transactions with different borrowing entities, concurrency is not warranted across those separate transactions. The direction of concurrency was also confined to the substantive sentences, because default sentences in lieu of fine or compensation do not fall within that concurrency direction.

Conclusion: The substantive sentences in complaints arising from the same transaction were directed to run concurrently, while sentences arising from distinct transactions were to run consecutively. The default sentences were left unaffected.

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