Interim compensation under cheque dishonour law is recoverable as a public demand through revenue recovery machinery.

Interim compensation ordered under Section 143A of the Negotiable Instruments Act is recoverable as if it were a fine under Section 421 CrPC, so it may be realised through the Collector as arrears of land revenue. Because the Bihar and Orissa Public Demands Recovery Act treats money declared by law to be recoverable in that manner as a public demand, such compensation falls within that recovery framework. The stated conclusion is that recovery under the Public Demands Recovery Act is maintainable and the challenge to enforcement fails.

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Issues: Whether interim compensation ordered under Section 143A of the Negotiable Instruments Act, 1881 can be enforced as a public demand under the Bihar and Orissa Public Demands Recovery Act, 1914.

Analysis: Section 143A(5) expressly provides that interim compensation may be recovered as if it were a fine under Section 421 of the Code of Criminal Procedure, 1973. Section 421(1)(b) authorises recovery through the Collector as arrears of land revenue. Section 3(6) of the Bihar and Orissa Public Demands Recovery Act, 1914, read with Article 3 of Schedule I, brings within the expression 'public demand' any money declared by law to be recoverable or realizable as arrears of revenue or land revenue through the authorised recovery process. On this statutory scheme, interim compensation ordered under Section 143A falls within the recovery mechanism of the Public Demands Recovery Act.

Conclusion: The enforceability of interim compensation under the Public Demands Recovery Act is upheld, and the challenge to such recovery fails.

Ratio Decidendi: Where a statute provides that interim compensation is recoverable as a fine under Section 421 of the Code of Criminal Procedure, 1973, the amount becomes recoverable through the Collector as arrears of land revenue and is a public demand under the Bihar and Orissa Public Demands Recovery Act, 1914.

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