Section 148 deposit orders are revisable, but waiver is confined to truly exceptional cases under the Negotiable Instruments Act.

A revision petition against an order directing deposit under Section 148 of the Negotiable Instruments Act is maintainable because such an order is not purely interlocutory where compliance may effectively curtail the right of appeal. The Court also explained that waiver of the statutory deposit is available only in rare and exceptional cases, such as deprivation of appellate rights or patent perversity in the conviction order, and not after a detailed reappraisal of evidence at the Section 148 stage. As the trial court had considered the rival contentions and the plea of financial hardship was unsubstantiated, no waiver was granted and the deposit direction was upheld.

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Issues: (i) whether a criminal revision petition is maintainable against an order directing deposit under Section 148 of the Negotiable Instruments Act, 1881; (ii) whether the facts disclosed a rare and exceptional case warranting waiver of the statutory deposit under Section 148.

Issue (i): whether a criminal revision petition is maintainable against an order directing deposit under Section 148 of the Negotiable Instruments Act, 1881.

Analysis: An order under Section 148 is not purely interlocutory where compliance may, in a given case, foreclose the appellant's right to pursue the appeal. The statutory setting, together with the Supreme Court's observation that deposit may be waived when it would amount to deprivation of the right of appeal, shows that such an order has consequences beyond a routine procedural direction. The Court also relied on the restoration of revision petitions in Jamboo Bhandari to conclude that a revision challenge is not barred by the interlocutory-order restriction.

Conclusion: The revision petitions were maintainable and the preliminary objection was rejected.

Issue (ii): whether the facts disclosed a rare and exceptional case warranting waiver of the statutory deposit under Section 148.

Analysis: The governing law, as explained through the sequence of decisions on Section 148, is that deposit is ordinarily to be directed, but a limited discretion survives for truly exceptional cases, including cases where deposit would be unjust, would deprive the appellant of the right to appeal, or where the conviction and sentence are, on a plain reading, so wholly incorrect or erroneous that deposit would be unnecessary. That discretion is only prima facie in nature and does not require a detailed reappreciation of evidence at the Section 148 stage. The trial court's order disclosed consideration of rival contentions and applicable law, and the petitioners' plea of financial hardship remained unsubstantiated.

Conclusion: No exceptional case for waiver was made out and the deposit direction was upheld.

Final Conclusion: The challenge to the deposit order failed, and the petitioners were required to comply with the appellate court's direction while their sentence remained suspended for the limited period granted.

Ratio Decidendi: A deposit order under Section 148 of the Negotiable Instruments Act, 1881 is ordinarily warranted, but a High Court may interfere in revision only where the case on a prima facie reading discloses a truly exceptional situation, such as deprivation of the right of appeal or patent perversity in the conviction order; a detailed reappraisal of evidence is impermissible at that stage.

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