Separate cheque dishonour offences cannot ordinarily be clubbed; joint trial depends on statutory limits and absence of prejudice.

Each dishonour of a cheque under section 138 of the Negotiable Instruments Act gives rise to a separate offence and separate cause of action, so joint trial is only available within the limited exceptions in sections 219, 220 and 223 of the Code of Criminal Procedure. The text explains that clubbing depends on statutory limits, sameness of transaction and absence of prejudice, and that section 219 permits only up to three offences of the same kind within twelve months. Where the cheques, dates, amounts, return memos and notices differ, and a belated clubbing request would prolong proceedings rather than expedite them, clubbing is not justified and section 482 interference is unwarranted.

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Issues: Whether five complaints under section 138 of the Negotiable Instruments Act, 1881 arising from dishonour of different cheques could be clubbed for a joint trial under sections 219, 220 and 223 of the Code of Criminal Procedure, 1973, and whether interference was warranted under section 482 of the Code of Criminal Procedure, 1973.

Analysis: Dishonour of each cheque gives rise to a separate offence and a separate cause of action. The provisions enabling joint trial are exceptions to the general rule of separate charge and separate trial, and their application depends on the statutory limits and on whether the offences form part of the same transaction without causing prejudice. On the facts, the cheques, dates, amounts, return memos and statutory notices were different, and the request for clubbing was moved belatedly after the accused's right of cross-examination had been closed. The requested clubbing was therefore not shown to serve expedition and was likely to delay the proceedings further. The court also noted that section 219 permits only up to three offences of the same kind within twelve months to be tried together.

Conclusion: Clubbing of the five complaints was not warranted, and no ground for interference in exercise of section 482 jurisdiction was made out.

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