Hari Kishan & Anr vs Sukhbir Singh & Ors on 25 August, 1988
"22. The provisions of Sections 357(3) and 431 Cr.P.C.,
when read with Section 64 IPC, empower the Court,
while making an order for payment of compensation, to
also include a default sentence in case of non-payment of
the same. The observations made by this Court in Hari
Singh's case (supra) are as important today as they were
when they were made and if, as submitted by Dr. Pillay,
recourse can only be had to Section 421 Cr.P.C. for
enforcing the same, the very object of Sub-section (3) of
Section 357 would be frustrated and the relief
contemplated therein would be rendered somewhat
illusory."