Cheque Dishonour and S.138 of Negotiable Instruments Act, 1881 : Who has the Right to File Appeal ?
It was held in Celestium Financial v. A. Gnanasekaran [2025] GCtR 1578 (SC) that "a person who is a complainant under Section 200 of the Code of Criminal Procedure, 1973 who complains about the offence committed by a person who is charged as an accused under Section 138 of the Negotiable Instruments Act, 1881 thus has the right to prefer an appeal as a victim under the proviso to Section 372 of the Code."