Concurrent sentencing in cheque dishonour cases may apply where convictions stem from one integrated course of transactions.

Successive cheque dishonour convictions arising from materially identical loan transactions between the same parties may be treated as part of a single integrated course of dealings for purposes of concurrent sentencing under Section 427 CrPC. Where the cheques were issued on the same terms and formed two segments of one transaction, the Court recognised discretion to direct the substantive sentences to run concurrently. The direction was confined to imprisonment; the default sentence remained operative if compensation was not deposited.

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Issues: Whether the substantive sentences imposed in two cheque dishonour cases arising out of similar transactions between the same parties should run concurrently under Section 427 of the Code of Criminal Procedure, 1973.

Analysis: The complaints arose from two materially identical transactions in which the complainant advanced loans to the appellant and the appellant issued cheques towards discharge of the debt, both of which were dishonoured. The Court held that the transactions formed part of a series between the same parties on the same terms and conditions, making them sufficiently integrated to be treated as a singular transaction or two segments of one transaction. Applying Section 427 of the Code of Criminal Procedure, 1973, and the settled principle that concurrent running of sentences depends on the nature of the offences and the overall facts, the Court found the appellant entitled to the benefit of that discretion. The direction for concurrency was confined to the substantive sentence.

Conclusion: The substantive sentences of imprisonment were directed to run concurrently, while the default sentences remained payable if the compensation was not deposited.

Final Conclusion: The appeals succeeded to the extent of ordering concurrency of the substantive sentences, thereby granting the appellant consequential relief in relation to custody.

Ratio Decidendi: Where successive convictions arise from a single integrated course of transactions between the same parties, the Court may direct the substantive sentences to run concurrently under Section 427 of the Code of Criminal Procedure, 1973, depending on the facts and circumstances of the case.

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