#Just decision

The Punjab & Haryana High Court has ruled that a complainant in a cheque bounce case under Section 138 NI Act can seek re-examination of themselves under Section 311 CrPC to establish financial capacity and debt liability, even after the defence is closed. This clarifies that judicial discretion under Section 311 extends to the complainant when essential for a just outcome, reinforcing procedural fairness in commercial criminal litigation.

The Madhya Pradesh High Court reaffirmed that trial courts retain discretion under Section 311 CrPC to recall witnesses even after evidence closure if essential for a just decision. This ruling underscores the primacy of natural justice over procedural finality, particularly in cheque dishonour cases where critical evidence may emerge late.

The Jharkhand High Court holds that trial courts may reopen prosecution evidence under BNSS 2023 if essential for a just decision, rejecting rigid application of civil procedure norms.