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Issues: Whether the petition under Section 482 of the Code of Criminal Procedure could be entertained to quash proceedings under Section 138 of the Negotiable Instruments Act on the ground that seven cheques formed separate causes of action and that Section 219 of the Code of Criminal Procedure barred clubbing of the complaints.
Analysis: The complaint alleged dishonour of seven cheques issued in connection with business dealings, and the revisional court had held that the allegations disclosed one offence. The disputed question whether the cheques arose out of one transaction or separate transactions could not be finally determined at the threshold. The applicability of Section 219 of the Code of Criminal Procedure was treated as a matter to be examined at trial, and the Court declined to decide factual controversies in exercise of inherent jurisdiction. The petitioner was left free to raise the available defence before the trial court.
Conclusion: The petition for quashing was not accepted, and the challenge to the cognizance and revisional order failed.