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Issues: Whether the appellate court can direct deposit of the amount under Section 148(1) of the Negotiable Instruments Act, 1881 within a period of less than sixty days, and whether the petitioner was entitled to a further extension of time beyond the period granted.
Analysis: Section 148(1) mandates deposit of a minimum of 20% of the fine or compensation amount in an appeal against conviction under Section 138 of the Act. Section 148(2) specifically allows sixty days from the date of the order for deposit, with a further period not exceeding thirty days on sufficient cause being shown. The appellate court has no discretion to curtail the statutory period of sixty days, and any direction requiring deposit within a shorter period is illegal. At the same time, the petitioner had already obtained extension under Section 148(2), and the circumstances did not justify granting three months more.
Conclusion: The direction requiring deposit within fifteen days was unsustainable, but the request for three months was declined and only a further thirty days from 22.02.2020 was granted.
Final Conclusion: The petitioner succeeded only to the extent of having the time limit under the impugned order corrected in accordance with the statute, while the prayer for a longer extension was rejected.
Ratio Decidendi: An appellate court cannot reduce the sixty-day statutory period for deposit under Section 148(2) of the Negotiable Instruments Act, 1881, and may grant only the further extension permitted by that provision on sufficient cause being shown.