Direct payment of compensation can be recorded without prior court deposit when the sentencing order expressly permits it.

Where a sentencing order permits direct payment of compensation to the complainant, the Magistrate may record that payment and make corresponding entries in the fine register without insisting on prior deposit in court, on proof through a memo or acknowledgment. The procedure is different where compensation forms part of a fine under Section 357(1) of the Code of Criminal Procedure, because fine-register and accounting requirements then apply, while compensation awarded separately under Section 357(3) stands on a different footing. The applicable Criminal Rules of Practice govern recording, collection, remittance, and accounting of fines and compensation. Finality of a criminal revision does not justify reopening the matter for a fresh settlement after disposal.

---

---

Issues: Whether, after disposal of a criminal revision or where the sentencing order itself permits direct payment, the Magistrate can record payment of compensation made directly to the complainant and make corresponding entries in the fine register without insisting on prior deposit in court; and how the procedure differs between compensation forming part of the fine under Section 357(1) of the Code of Criminal Procedure, 1973 and compensation awarded separately under Section 357(3) of the Code of Criminal Procedure, 1973.

Analysis: The finality of a revision does not permit reopening of the case for a fresh settlement after disposal, but where the sentence itself authorises direct payment to the complainant, the payment can be recognised in accordance with the order. Compensation forming part of a fine has to follow the fine-register procedure, whereas compensation awarded separately under Section 357(3) stands on a different footing. The relevant Criminal Rules of Practice govern recording, collection, remittance, and accounting of fines and compensation. Where the court has specifically permitted direct payment to the complainant, the Magistrate need not insist on prior deposit in court, and on proof of payment through a memo or acknowledgment, the payment may be entered in the register. The earlier decision was therefore held to be correctly applied on its facts and not shown to be generally erroneous.

Conclusion: Direct payment to the complainant can be recorded and entered in the fine register where the sentencing order permits such payment, and the Magistrate cannot insist on court deposit in such a case. The distinction between compensation under Section 357(1) and Section 357(3) was affirmed.

---