In In Re: Expeditious Trial of Cases under Section 138 of N.I. Act, 1881 (2021), a Constitution Bench…

In Meters and Instruments Private Limited v. Kanchan Mehta, (2018) 1 SCC 560, a two-Judge Bench had held that where the cheque amount with assessed interest and costs is paid by a specified date, the trial court could close the proceedings under Section 143 of the Negotiable Instruments Act, 1881 read with the power to stop proceedings in summons-cases—now Section 281 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (formerly Section 258 of the Code of Criminal Procedure, 1973)—even without the complainant's consent. In In Re: Expeditious Trial of Cases under Section 138 of N.I. Act, 1881, (2021) 16 SCC 116, a five-Judge Constitution Bench overruled Meters and Instruments on this point, holding that the power to stop proceedings applies only to summons-cases instituted otherwise than upon complaint and that compounding under Section 147 of the Negotiable Instruments Act, 1881 requires the consent of the complainant. K.M. Ibrahim v. K.P. Mohammed (2010), Damodar S. Prabhu v. Sayed Babalal H. (2010), and M.P. State Legal Services Authority v. Prateek Jain (2014) concern voluntary compounding under Section 147 and the graded scale of compounding costs.