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Dis. Cheques - Speculative prosecution of Directors of the Company …

Dis. Cheques – Directors’ Crim. Liab – Injudicious approach so far …

  1. In this write up, I intend to deal with an issue which I think is not judiciously dealt with, although there are hundreds of precedents which otherwise have dealt with the issue.

  1. Recently I had happened to closely witnessed a case of offence u/s 138 of of Negotiable Instruments Act, 1881, i.e., of dishonoured cheque, wherein in the Complaint, it was barely averred that the “…. are Directors of the Company and are in-charge of the day to day affairs of the business of the accused company”, and the Magistrates Court happily issued processes (Summons) against all those Directors.

  1. The Directors therein preferred Revision Application before the Sessions Court, thereby challenging the issuance of said Summons. The said Revision was founded on the grounds that the impugned Order passed by the Ld. Magistrate is in breach of the mandate of Section 204 of the CrPC, 1973, and is in breach of the mandate of Section 141 of the Negotiable Instruments Act, 1881.

  1. In support of the contentions, some 4-5 SC authorities were cited. However, the Ld. Session Judge remained unimpressed, and he happily dismissed the said Revision Application.

  1. In the said Revision Application, a broad principal issue was raised before the Court, and that is – Whether the Directors of a Company can be told to face a Criminal trial, based on the mere 2 lines averments in the Criminal Complaint, without any other evidence of whatsoever nature.

The said 2 lines are
….are Directors of the Accused Company and are in-charge of the day to day affairs of the business of the accused company.

  1. And whereas the impugned order is passed under Section 204 of CrPC, 1973; under a Complaint u/s 200 of CrPC, 1973, for having committed an offence u/s 138 read with 141 of the negotiable Instruments Act, 1881, the Hon’ble Court were to satisfy itself as – (a) Whether the impugned order of the Ld. Magistrate pass the test of the mandate of law of Sections 204 of CrPC, 1973; and Section 141 of the Negotiable Instruments Act, 1881.

  1. The relevant portion of Section 204 of Criminal Procedure Code, 1973 and Section 141 of the Negotiable Instruments Act, 1881, were reproduced –

Section 204. Issue of process: (1)If in the opinion of a Magistrate taking cognizance of an offence there is sufficient ground for proceeding, and the case appears to be – a summons- case, he shall issue his summons for the attendance of the accused, or a warrant- case, he may issue a warrant, or, if he thinks fit, a summons, for causing the accused to be brought or to appear at a certain time before such Magistrate or (if he has no jurisdiction himself) some other Magistrate having jurisdiction.

Section 141: - Offence by companies - (1) If the person committing an offence under section 138 is a company, every person who, at the time the offence was committed, was in charge of, and was responsible to, the company for the conduct of the business of the company, as well as the company, shall be deemed to be guilty of the offence and shall be liable to be proceeded against and punished accordingly.

Provided that nothing contained in this sub-section shall render any person liable to punishment if he proves that the offence was committed without his knowledge, or that he had exercised all due diligence to prevent the commission of such offence."

  1. In support of contentions, in respect of section 141 of Negotiable Instruments Act, 1881, apart from other authorities, it was strongly, although erroneously,  relied upon SMS Pharmaceuticals judgment (three Judges Bench), which later, it was realize that, we grossly erred in understanding the ratio of the judgment.

  1. Although, however, later judgments of the Apex court on section 141, which though have relied upon the said SMS judgment, but progressed to a more rational proposition of law.

  1. The said SMS Pharma judgment, in essence, laid down that if the Complainant barely avers in his Complaint that “the said persons are Directors of the Company and are in-charge of the day to day affairs of the business of the accused company”, the said complainant complies to the requirements laid down under section 141.

  1. The later judgments, like for example, in the case of Ramraj Singh versus State of M.P. (2009) 6 SCC 729, also delivered by three Judges Bench, the Apex Court, inter alia, in Para 10, cited an Apex Court ruling, progressed to a more rational proposition, in respect of the compliance to section 141. The said judgment also relied upon the SMS judgment.

Para 10 In N.K. Wahi V/s. Shekhar Singh and Ors. (2007 (9) SCC 481) it was observed as follows:

8. To launch a prosecution, therefore, against the alleged Directors there must be a specific allegation in the complaint as to the part played by them in the transaction. There should be clear and unambiguous allegation as to how the Directors are incharge and responsible for the conduct of the business of the company. The description should be clear. It is true that precise words from the provisions of the Act need not be reproduced and the court can always come to a conclusion in facts of each case. But still in the absence of any averment or specific evidence the net result would be that complaint would not be entertainable.

  1. In respect of section 204 of the CrPC, 1973, a very recent ruling of the Apex Court was relied upon, and attention of the Court was invited to the case of GHCL Employees Stock Option Trust versus India Infoline Ltd – (2013) 4 SCC 505, which dealt with the issuance of Summons by the Magistrates u/s 204, in the exercise of their powers u/s 200 of CrPC, 1973. The Hon’ble SC in Para 9, 18, and 19 stated as –

Para 9: Per contra, Dr. Abhishek Manu Singhvi, learned Senior Counsel appearing for the respondents in all the cases, at the very outset submitted that the High Court has correctly quashed the criminal proceedings initiated against the Managing Director, the Company Secretary, and other Directors of the Company, holding that there cannot be vicarious liability; and moreover, needs to specifically allege the act complaint of against the individual Director and what role such individual Director had played. The learned Counsel submitted that the Complainant made a general averment that Respondent Nos.2 to 7 were responsible for day-to-day affairs of the Company, without specifying the exact role played by them in the transaction.

Para 18.From bare perusal of the order passed by the Magistrate, it reveals that two witnesses including one of the trustees were examined by the complainant but none of them specifically stated as to which of the accused committed breach of trust or cheated the complainant except general and bald allegations made therein. While ordering issuance of summons, the learned Magistrate concluded as under :-

“The complainant has submitted that the accused Nos.2 to 6 are the directors of the company and accused No.7 is the secretary of the company and were looking after the day to day affairs of the company and were also responsible for conduct and business of the accused No.1 and some time or the other have interacted with the complainant.

I have heard arguments on behalf of the complainant and perused the record. From the allegations raised, documents placed on record and the evidence led by the witnesses, prima facie an offence u/s 415, 409/34/120B is made out. Let all the accused hence be summoned to face trial under the aforesaid sections on PF/RC/Speed Post/courier for 2.12.2008.”

Para 19: In the order issuing summons, the learned Magistrate has not recorded his satisfaction about the prima facie case as against respondent Nos.2 to 7 and the role played by them in the capacity of Managing Director, Company Secretary or Directors which is sine qua non for initiating criminal action against them. 

  1. The Hon’ble SC in the case of Pepsi  Foods  Ltd.  and  Anr.  v. Special Judicial  Magistrate & Ors (1998) 5 SCC 749), inter alia, observed  as –

Summoning of an accused in a criminal  cases  is  a  serious matter.  Criminal  law  cannot  be set  into  motion  as  a  matter  of course.  It  is  not  that  the complainant  has  to  bring  only two  witnesses  to  support  his allegations in the complaint to have  the  criminal  law  set  into motion.  The  order  of  the magistrate summoning the accused must reflect that he has applied his  mind  to  the  facts  of  the case  and  the  law  applicable thereto.  He  has  to  examine  the nature  of  allegations  made  in the  complaint  and  the  evidence both  oral  and  documentary  in support  thereof  and  would  that be  sufficient  for  the complainant  to  succeed  in bringing  charge  home  to  the accused.  It  is  not  that  the Magistrate is a silent spectator at  the  time  of  recording  of preliminary  evidence  before summoning  of  the  accused. Magistrate  has  to  carefully scrutinize  the  evidence  brought on  record  and  may  even  himself put questions to the complainant and  his  witnesses  to  elicit answers  to  find  out  the truthfulness  of  the  allegations or otherwise and then examine if any  offence  is  prima  facie committed  by  all  or  any  of  the accused.


  1. There are numerous HC and SC rulings on sections 138 and 141, but there is not a single ruling I could find, which have tested the issuance of Summons by the Magistrates at the touchstone of section 204 of CrPC, 1973, and where such Summons are challenged, the HCs and SC were happily dismissing the Applications, after having satisfied themselves to have tested the issuance of Summons at the touchstone of SMS Pharma judgment.

  1. Surprisingly enough, it was never realized by the Courts that whereas Summons are issued u/s 204 of CrPC, 1973, and therefore, the requirements of section 204 has to be met with.

  1. Moreover, it has not been realized that, although, however, bare averments in the Complaint “…said persons are Directors of the Company and are in-charge of the day to day affairs of the business of the accused company”, may satisfy the requirements of section 141, but these averments does not satisfy the requirements of section 204, under which the Summons / process is issued.

  1. Howsoever laudable objects Sections 138 to 147 of the Negotiable Instruments Act, 1881, may be holding, the personal liberty of an individual and rule of law is paramount. The mandate inherent in Section 204 cannot be sacrificed / dispensed with, to serve the “laudable objects” of Chapter 17 of the Negotiable Instruments Act.

  1. It is imperative that mandate of Section 204 is scrupulously observed, so to protect the interest of a person who has no right of representation at the stage of magistrate taking cognizance of an offence and issuing summons / warrants against the said person; and also when, the Magistrate has no power to recall his summons, and the aggrieved may have to adopt independent proceedings to set aside the order of summons.

  1. If the processes are being issued on the basis of bare averments in the Complaint that “the said persons are directors of the accused company and are in charge of day to day affairs of the business of the accused company”, without any other evidence of whatsoever nature, the prosecution admittedly becomes speculative.

  1. Also, it needs to be think upon that, during the course of trial, is it really possible to convict directors based on these bare averments, especially when the accused has right to remain silent; and there is no presumption of law “that Directors of the Company shall be deemed to be in-charge of the affairs of the day-to-day business of the Company, unless otherwise proved.

  1. Institution of any judicial proceedings against a person carries an implicit degree of coercion and no judicial proceedings should be triggered at the whims and fancies of the litigants, which otherwise amounts to sheer harassment, embarrassment, and substantial expenses to the person saddled with unwarranted litigation and most importantly, causes the waste of the precious time of the court in hearing the frivolous and meritless litigations.

  1. Article 21 of the Constitution of India commands that “No person shall be deprived of his life and liberty” except according to the procedure established by law. In Criminal jurisprudence, the only safeguard available to an innocent person is the “scrupulous and strict adherence” to the procedure prescribed in concluding the “guilt of the accused person”.

  1. Thus, whenever, any of the “prescribed procedure” is not “duly followed and complied with”, and where such non compliance, expressly or by necessary implication, frustrate the personal liberty of the accused person, the violence to fundamental right of the concerned person enshrined under Article 21 of the Constitution, is imminent.

  1. And, whereas the innocent Directors of the Company needs to be protected, unscrupulous Directors should not escape by virtue of any interpretation of law. A solution should be devised to address this issue.

  1. In my view, at the stage of issuing of statutory notice u/s 138, to the company, the payee shall also sent notice to every individual Director of the Company, at their residential address, inter alia, calling upon them to show cause, why the payee should not proceed against them, in case the company fails to pay the dishonored cheque debt.

  1. Further, the Magistrate, before issuing summons u/s 204, may exercise the power conferred to them u/s 202, and by taking such steps, may ascertain who are the Directors who are in-charge of the affairs of the day-to-day business of the Company.

  1. The measures suggested hereinbefore in paras 26 and 27 may not inspire satisfaction, nevertheless, the personal liberty of directors cannot be jeopardized, or else, the persons may be afraid of taking up the Directorship of a Company, and credible Directors may end up defending their innocence in the court of law, for long years, in multiple litigations, that may spread over throughout India. This will not be a healthy climate for the development of the business and the economy.

Thanking you.
Sandeep Jalan
Advocate
Mumbai

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Thank you.

Comments

navsky said…
http://www.498a.org/dvfaq.htm

I read this after you told me. Pretty horrifying.

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