Single complaint for multiple dishonoured cheques upheld where all cheques arose from one commercial transaction and one cause of action.

A single complaint was maintainable for dishonour of 14 cheques issued in the course of the same commercial dealings. The Court held that, where the cheques arose from a running account and formed part of one transaction, Section 219 CrPC did not bar joinder merely because multiple cheques were involved. It noted that the cause of action under Section 138 of the Negotiable Instruments Act arises on failure to pay after notice, and that splitting charges or trials is a matter for the trial court. The objection to the complaint was rejected and the complaint was held maintainable.

---

---

Issues: Whether a single complaint was maintainable in respect of dishonour of 14 cheques issued in the course of the same business dealings, or whether Section 219 of the Code of Criminal Procedure barred such joinder.

Analysis: The complaint arose out of a running commercial account and the cheques were issued on different dates in relation to the same transaction. The Court noted the settled view that dishonour of multiple cheques does not by itself render a single complaint invalid where the cheques form part of one transaction and the cause of action under Section 138 of the Negotiable Instruments Act arises on failure to pay after notice. The Court also relied on the principle that the stage for splitting charges or trials is for the trial court to examine, and that a complaint referring to several cheques is not bad in law merely because more than three cheques are involved.

Conclusion: The objection based on Section 219 of the Code of Criminal Procedure was rejected and the single complaint was held maintainable.

---