Procedural fairness in cheque dishonour trials cannot be sacrificed for speed; denial of cross-examination can justify remand.

Expeditious disposal of Negotiable Instruments Act prosecutions does not justify denial of a meaningful opportunity to cross-examine the complainant or other basic procedural safeguards. Where the trial court proceeded hurriedly, recorded the complainant's evidence and the accused's Section 313 CrPC statement on the same day, and thereby prejudiced the defence, the criminal process was found to offend natural justice. The concurrent findings were set aside and the matter was remanded for fresh trial after granting both sides a proper opportunity to adduce evidence.

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Issues: Whether the conviction and sentence under Section 138 of the Negotiable Instruments Act, 1881 could be sustained when the accused was denied an effective opportunity to cross-examine the complainant and the trial court adopted an unduly hurried procedure, warranting interference in revision and remand for fresh trial.

Analysis: The record showed that the accused was brought before the trial court, bail was granted, plea was recorded, the complainant's sworn statement was treated as evidence, and the statement of the accused under Section 313 of the Code of Criminal Procedure, 1973 was recorded on the same day, with the matter being progressed without granting a meaningful opportunity for cross-examination. The revisional court held that the directions for expeditious disposal of Negotiable Instruments Act cases do not authorise denial of basic procedural fairness. It was found that the hurried course adopted by the trial court had prejudiced the accused and offended the requirements of natural justice. The appellate court also failed to correct this procedural illegality.

Conclusion: The conviction and sentence could not be sustained. The revision was allowed, the concurrent findings were set aside, and the matter was remanded for fresh trial in accordance with law after affording both sides proper opportunity to lead evidence.

Ratio Decidendi: A criminal conviction cannot be sustained where the accused is denied a meaningful opportunity to cross-examine and the trial is conducted in a manner that undermines natural justice, even in cases requiring expeditious disposal.

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