Bijay Agarwal vs Medilines  2024 INSC 918- Ss 138,148,141 Negotiable Instruments Act

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Can the signatory of a cheque authorized by the Company is a drawer ? Can such a signatory could be directed to deposit any sum out of the fine or compensation awarded by the trial Court under Section 148 of the Negotiable Instruments Act, 1881 as a condition for suspending the sentence in an appeal filed against his conviction under Section 138 of the NI Act? 

Negotiable Instruments Act, 1881 – Section 138,141, 148 – Merely because an officer of a company  concerned is the authorised signatory of the cheque  concerned by itself will not make such an officer  ‘drawer of the cheque’ under Section 148, NI Act, so as  to empower the Appellate Court, in an appeal against  conviction for an offence under Section 138, NI Act, to  direct to deposit compensation of any sum under  Section 148(1), of the NI Act. (Para 16)

Negotiable Instruments Act, 1881 – Section 148  An Appellate Court in an appeal against conviction under Section   138, NI Act, could not place a condition to deposit an   amount invoking the power under Section 148(1), NI Act, mechanically without considering whether the case   falls within exceptional circumstances. (Para 17)

Negotiable Instruments Act, 1881 – Section 138,141, 143A -The primary liability for an  offence under Section 138 lies with the company and  the company’s management is vicariously liable only  under specific conditions provided in Section 141 and  for the purpose of Section 143A of the NI Act and a  signatory merely authorised to sign on behalf of the  company would not become the ‘drawer’ of the cheque and, therefore, could not be directed to pay interim  compensation under Section 143A. (Para 13)