Appellate deposit in cheque dishonour cases is governed by Section 148 after conviction, not Section 143A at trial.

Section 143A of the Negotiable Instruments Act applies at the trial stage and authorises interim compensation, up to 20% of the cheque amount, on sufficient cause. Section 148 applies at the appellate stage after conviction and empowers the appellate court, when considering suspension of sentence, to direct deposit of at least 20% of the fine or compensation awarded by the trial court. Because the impugned direction was made after conviction during appeal, it was properly traceable to Section 148 and not Section 143A. The statutory challenge disclosed no infirmity in the order, and the deposit direction was upheld.

---

---

Issues: Whether the appellate court was justified in directing deposit of 20% of the cheque amount while suspending sentence under Section 389(1) of the Code of Criminal Procedure, 1973, and whether such direction could be treated as one under Section 143A of the Negotiable Instruments Act, 1881.

Analysis: Section 143A of the Negotiable Instruments Act, 1881 applies at the trial stage and permits interim compensation on sufficient cause being shown, with the amount not exceeding 20% of the cheque amount. Section 148 of the Negotiable Instruments Act, 1881 operates at the appellate stage after conviction and empowers the appellate court to direct deposit of a minimum of 20% of the fine or compensation awarded by the trial court. The impugned order was passed after conviction, in the context of suspension of sentence during appeal, and was therefore traceable to Section 148 rather than Section 143A. The challenge proceeded on a understanding of the statutory scheme and disclosed no infirmity in the order.

Conclusion: The direction to deposit 20% was valid and the challenge to the appellate court's order failed.

---