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High Court of Gujarat

BHAVIKBHAI YATINBHAI PATELversusSTATE OF GUJARAT

Disposal
38-RULE ABSOLUTE/ALLOWED @ FH

Holding

The High Court suspended the sentence subject to a personal bond and surety of Rs.10,000 each and imposed conditions, thereby allowing the revision application.

Summary

Bhavikbhai Yatinbhai Patel was convicted under Section 138 of the Negotiable Instruments Act, 1881 for issuing a cheque of Rs.1,60,000 that later bounced. The appellant had already deposited 20% of the amount before the Appellate Court and submitted the receipt to the High Court. He applied for a revision seeking suspension of the sentence and bail, arguing that the partial payment warranted relief. The Additional Public Prosecutor opposed any discretionary relief. The Court, noting the partial payment and the pending revision, ordered the suspension of the sentence pending the appellant’s furnishing a personal bond and a surety of Rs.10,000 each, subject to conditions of compliance, non‑misuse of liberty, and no travel abroad without permission. The application was therefore allowed, and the order of sentence was stayed until the revision is decided.

Issues considered

  • Whether the sentence imposed under Section 138 of the Negotiable Instruments Act can be suspended pending a revision application when a part of the liability has been paid.

Legislation cited

Subjects

Negotiable Instruments ActSection 138cheque bouncerevisionsuspension of sentencebailpersonal bondsurety

Judgment

     R/CR.RA/904/2026                             ORDER DATED: 01/04/2026




            IN THE HIGH COURT OF GUJARAT AT AHMEDABAD


     R/CRIMINAL REVISION APPLICATION (AGAINST CONVICTION -
          NEGOTIABLE INSTRUMENT ACT) NO. 904 of 2026

================================================================
                        BHAVIKBHAI YATINBHAI PATEL
                                  Versus
                         STATE OF GUJARAT & ANR.
================================================================
Appearance:
VISHAL K ANANDJIWALA(7798) for the Applicant(s) No. 1
MS JYOTI BHATT, ADDITIONAL PUBLIC PROSECUTOR for the
Respondent(s) No. 1
================================================================

 CORAM:HONOURABLE MS. JUSTICE GITA GOPI

                              Date : 01/04/2026

                                  ORDER


1.     RULE.        Learned   Additional Public   Prosecutor        waives
       service of notice of Rule on behalf of respondent–State.


2.     By way of this application, the challenge is given to the
       concurrent %ndings of conviction and sentence passed
       under Section 138 of the Negotiable Instruments Act,
       1881.


3.     Learned advocate for the applicant submits that an
       amount of Rs.1,60,000/- has already been deposited
       before the learned Appellate Court. Learned advocate for
       the applicant also produces before this Court a copy of
       the receipt of the above payment. It was, therefore,
       prayed that the present application may be allowed and


                                  Page 1 of 3
     R/CR.RA/904/2026                          ORDER DATED: 01/04/2026




       the sentence qua the applicant herein may be suspended
       and the applicant be granted bail.


4.     Learned Additional Public Prosecutor prayed that no
       discretion may be exercised in favour of the applicant.


5.     Heard learned advocates appearing for the respective
       parties and perused the material on record. Taking into
       consideration the facts and circumstances of the case
       and when 20% of the amount has been deposited before
       the learned Appellate Court and when the Revision
       Application will take its own time to come for %nal
       hearing, the order of sentence requires consideration.


6.     In view of the above, the order of sentence dated
       29.05.2025 passed by the learned Principal Civil Judge
       and JMFC, Sojitra in Criminal Case No.28 of 2020, which
       was upheld and con%rmed by order dated 13.03.2026
       passed by the learned 3rd Additional District and Sessions
       Judge, Petlad in Criminal Appeal No.49 of 2025 are
       suspended till disposal of the Revision on applicant’s
       furnishing personal bond of Rs.10,000/- (Rupees ten
       thousand only) and a surety of like amount to the
       satisfaction of the Trial Court concerned and subject to
       the conditions that the applicant shall:-
       [a]     pursue the matter scrupulously as and when the
               same is listed;
       [b]     not take undue advantage of liberty or misuse
               liberty;


                                 Page 2 of 3
          R/CR.RA/904/2026                                                         ORDER DATED: 01/04/2026




            [c]        not leave India without prior permission of the
                       Court;


  7.        If breach of any of the above conditions is committed, the
            Sessions Judge concerned will be free to issue warrant or
            take appropriate action in the matter.


  8.        Accordingly, the present application is allowed in the
            above terms. Rule is made absolute to the aforesaid
            extent.           Direct          service           is      permitted.              Registry            to
            communicate this order to the concerned Court/authority
            by Fax or Email forthwith.
                                                                                                        Sd/-

                                                                                                (GITA GOPI, J)
  CAROLINE / SB-1 # 6


Original copy of this order has been signed by the Hon'ble Judge.
Digitally signed by: CAROLINE ANTHONISWAMY(HC00212), Principal pvt Secretary, at High Court of Gujarat on 01/04/2026 15:13:20




                                                      Page 3 of 3


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