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    <title>2022 (9) TMI 893 - KARNATAKA HIGH COURT</title>
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    <description>Section 148 of the Negotiable Instruments Act, 1881 was interpreted as requiring a mandatory minimum deposit of 20% of the fine or compensation in an appeal against conviction under Section 138. The court read the amended provision as leaving no discretion to reduce the statutory deposit below that threshold, relying on its text and object of curbing delay and protecting the payee of a dishonoured cheque. The amendment was also treated as applicable to pending appeals even where the complaint had been filed before the amendment, because no vested substantive right of appeal was taken away and the non obstante clause overrode the general Criminal Procedure Code rule.</description>
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      <description>Section 148 of the Negotiable Instruments Act, 1881 was interpreted as requiring a mandatory minimum deposit of 20% of the fine or compensation in an appeal against conviction under Section 138. The court read the amended provision as leaving no discretion to reduce the statutory deposit below that threshold, relying on its text and object of curbing delay and protecting the payee of a dishonoured cheque. The amendment was also treated as applicable to pending appeals even where the complaint had been filed before the amendment, because no vested substantive right of appeal was taken away and the non obstante clause overrode the general Criminal Procedure Code rule.</description>
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