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Subramanium Sethuraman vs State Of Maharashtra & Anr on 17 September, 2004

Expeditious Trial of Cases under Section 138 of the NI Act suo moto writ petition (Crl. No. 2/2020) decided on April 16, 2021 has also categorically ruled that the judgements of the court in Adalat Prasad (supra) and Subramanium (supra) had interpreted law correctly and reiterated that there is no inherent power of the trial courts to review or recall or to reviews of summons.
Supreme Court of India Cites 6 - Cited by 266 - Full Document

K.M. Mathew vs State Of Kerala And Anr on 19 November, 1991

The observation in the case of K. M. Mathew (supra) that no specific provision of law is required for recalling an erroneous order of issue of process was held to be contrary to the scheme of the Code in Adalat Prasad v. Rooplal Jindal and Others9. It was observed therein that the order taking cognizance can only be subject matter of a proceeding under Section 482 of the Code as subordinate criminal courts have no inherent power. There is also no power of review conferred on the Trial Courts by the Code.
Supreme Court of India Cites 13 - Cited by 328 - K J Shetty - Full Document

Adalat Prasad vs Rooplal Jindal & Ors on 25 August, 2004

The observation in the case of K. M. Mathew (supra) that no specific provision of law is required for recalling an erroneous order of issue of process was held to be contrary to the scheme of the Code in Adalat Prasad v. Rooplal Jindal and Others9. It was observed therein that the order taking cognizance can only be subject matter of a proceeding under Section 482 of the Code as subordinate criminal courts have no inherent power. There is also no power of review conferred on the Trial Courts by the Code.
Supreme Court of India Cites 19 - Cited by 900 - Full Document

M/S Meters And Instruments Private ... vs Kanchan Mehta on 5 October, 2017

7. Section 258 of the Code is not applicable to complaints under Section 138 of the Act and findings to the contrary in Meters and Instruments (supra) do not lay down correct law. To conclusively deal with this aspect, amendment to the Act empowering the Trial Courts to reconsider/recall summons in respect of complaints under Section 138 shall be considered by the Committee constituted by an order of this Court dated 10.03.2021.
Supreme Court of India Cites 48 - Cited by 753 - A K Goel - Full Document
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