Expeditious trial in cheque dishonour complaints: court directs speedy disposal and lawful steps to secure accused attendance.

Complaint proceedings under Section 138 of the Negotiable Instruments Act must be conducted with procedural expedition, as the statutory scheme under Sections 138 and 143 contemplates prompt trial and binding Supreme Court directions favour day-to-day progress in cheque dishonour matters. The Court directed expeditious disposal of a long-pending complaint, preferably within six months of receipt of the certified copy of the order, and confirmed that the trial court may use lawful coercive measures to secure the accused's attendance where necessary.

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Issues: Whether directions were warranted for expeditious disposal of a long-pending complaint under Section 138 of the Negotiable Instruments Act, 1881, and for ensuring the accused's appearance during trial.

Analysis: The complaint had remained pending since 2014. The statutory scheme under Sections 138 and 143 of the Negotiable Instruments Act, 1881 contemplates prompt and efficient trial, and the Court relied on the Supreme Court's directions emphasising day-to-day progress and expeditious disposal of cheque dishonour cases. The Court also noted that the trial court must proceed in accordance with the statutory framework and may take coercive steps where necessary to secure the presence of the accused during trial.

Conclusion: Directions were issued to conclude the trial expeditiously, preferably within six months of receipt of the certified copy of the order, and to use lawful coercive measures to secure the accused's presence if required.

Final Conclusion: The application succeeded to the extent of obtaining a time-bound direction for speedy disposal of the pending complaint and effective trial management.

Ratio Decidendi: Complaints under Section 138 of the Negotiable Instruments Act, 1881 must be prosecuted with procedural expedition in accordance with the statutory mandate and binding Supreme Court directions, and trial courts may adopt coercive measures permitted by law to secure the accused's attendance.

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