Concurrent sentencing for multiple cheque dishonour convictions may apply where transactions form a single series of dealings.

Multiple convictions under section 138 of the Negotiable Instruments Act arising from successive transactions between the same parties and based on substantially the same evidence may be treated as part of a single series of dealings. On that basis, the Court noted that inherent jurisdiction under section 482 of the Code of Criminal Procedure can be used to direct substantive sentences to run concurrently where the transactions show sufficient identity, including cheques issued toward a common liability. The commentary also notes that such concurrency may be granted while leaving default sentences unaffected if fines remain unpaid.

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Issues: Whether the substantive sentences imposed in three complaint cases under section 138 of the Negotiable Instruments Act could be directed to run concurrently in exercise of inherent powers under section 482 of the Code of Criminal Procedure.

Analysis: The complaints arose out of successive transactions between the same parties, were tried on substantially the same evidence, and concerned cheques issued towards discharge of a common rental liability. The facts showed sufficient identity in the nature of the transactions to treat them as forming a single series of dealings. In these circumstances, the Court held that the petitioner was entitled to the benefit of judicial discretion for ordering concurrent running of the substantive sentences.

Conclusion: The direction for concurrent running of the substantive sentences was warranted and granted in favour of the petitioner.

Final Conclusion: The petition succeeded, and the petitioner obtained relief that the substantive custodial sentences in the three complaint cases would run concurrently, while the default sentences remained unaffected if fines were unpaid.

Ratio Decidendi: Where multiple convictions arise from substantially identical transactions between the same parties and form part of a single series of dealings, the Court may, in exercise of inherent jurisdiction, direct the substantive sentences to run concurrently.

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