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of HC ruled that criminal proceedings under NI Act for cheque dishonor do not automatically abate upon accused's death during pendency of revision application. While no explicit definitions exist for fine or compensation in CrPC/IPC, compensation ordered under Sections 138/141 of NI Act is recoverable from deceased's estate similar to fine under Sections 421 and 431 CrPC. The Rs. 12 Lakh compensation awarded remains enforceable against the deceased's legal heirs through property auction/sale proceedings. Court directed substitution of legal representatives in place of deceased accused and held case would continue for recovery of compensation, treating it equivalent to fine for enforcement purposes. Application for substitution of legal heirs allowed.
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