$~P-1 to 6 * IN THE HIGH COURT OF DELHI AT NEW DELHI Reserved on: 28.01.2026 Pronounced on: 25.03.2026 Uploaded on: 25.03.2026 + CRL.M.C. 2398/2019 & CRL.M.A. 9511/2019 MANISH GOYAL .....Petitioner versus S P REALTORS .....Respondent + CRL.M.C. 5769/2019 & CRL.M.A. 40220/2019 MANISH GOYAL .....Petitioner versus HARLEEN KAUR SACHDEVA & ANR .....Respondents + CRL.M.C. 621/2020 & CRL.M.A. 2574/2020 MANISH GOYAL .....Petitioner versus GAGAN PREET SINGH & ANR. .....Respondents + CRL.M.C. 644/2020 & CRL.M.A. 2689/2020 MANISH GOYAL .....Petitioner versus S.P. REALTORS .....Respondent + CRL.M.C. 668/2020 & CRL.M.A. 2766/2020 MANISH GOYAL .....Petitioner versus HARLEEN KAUR SACHDEVA & ANR. .....Respondents + CRL.M.C. 669/2020 & CRL.M.A. 2768/2020 MANISH GOYAL .....Petitioner versus GAGAN PREET SINGH & ANR. .....Respondents Appearance:

Mr. Kunal Kher, Advocate for petitioner.

Mr. Ashok K. Goyal, Mr. Bhupender M. Sharma and Ms. Prerna Goyal, Advocates for respondents.

CORAM:

HON’BLE MR. JUSTICE PRATEEK JALAN

J U D G M E N T

1. By way of these petitions filed under Section 482 of the Code of Criminal Procedure, 1973, the petitioner seeks quashing of summoning orders dated 22.05.2017 in Complaint Case Nos. 4849/2017, 4850/2017 and 4852/2017 [subject matter of CRL.M.C 621/2020, CRL.M.C 5769/2019, CRL.M.C 2398/2019 respectively], as well as summoning orders dated 01.07.2017 in Complaint Case Nos. 2814/2017, 2815/2017 and 2819/2017 [subject matter of CRL.M.C 669/2020, CRL.M.C 668/2020, CRL.M.C 644/2020 respectively], passed by the Magistrate’s Court, Rohini Courts, Delhi. The petitioner also seeks quashing of all criminal proceedings against him emanating from the impugned summoning orders.

A. FACTS

2. The relevant facts giving rise to the present petitions are as follows:

A. The petitioner was appointed as an Additional Director in M/S Piyush Colonisers Limited [“the Company”] on 19.02.2015.

B. The petitioner’s designation was changed to an Independent Director [Non-Executive Director] on 30.09.2015.

C. The Company entered into three separate agreements to lease dated

10.03.2016, 07.11.2017, and 09.11.2017. Under these agreements, three units bearing Nos. 101, 104, and 106 at a building named M/S Piyush Global, First Floor, Plot No. 5, YMCA Chowk, Main Mathura Road, Faridabad, Haryana – 121006, were let out to the Company at a fixed monthly rent. The Company issued multiple cheques to pay the rent, but they were dishonoured when presented.

Details of the concerned cheques are tabulated as follows:

D. Pursuant to the dishonour, the respondents issued separate legal notices dated 07.04.2017 and 17.05.2017, but no response was received. Consequently, the respondents filed complaints under Section 138 read with Section 141 of the Negotiable Instruments Act, 1881 [“NI Act”], against the Company and its directors, including the petitioner herein.

E. The Magistrate’s Court took cognizance of the offences and issued the impugned summoning orders dated 22.05.2017 and 01.07.2017.

B. SUBMISSIONS OF LEARNED COUNSEL FOR THE PARTIES

3. I have heard Mr. Kunal Kher, learned counsel for the petitioner, and Mr. Ashok Kumar Goyal, learned counsel for the respondents.

4. The principal ground taken by Mr. Kher is that the complaint filed by the respondents does not make out the necessary grounds under Section 141 of the NI Act to hold the petitioner vicariously liable for the Company’s offences under Section 138 of the NI Act. Mr. Kher submits that the complaints only contain vague and general assertions, and are devoid of specific averments required to show that the offence was within the knowledge/consent of the petitioner. To this effect, he relies upon a judgment of the Supreme Court in K.S. Mehta v. Morgan Securities and Credits Pvt. Ltd., 2025 SCC OnLine SC 492 [hereinafter, “KS Mehta”]., and a judgment of a coordinate Bench of this Court in Rahul Sood v. Government of NCT of Delhi, 2025 SCC OnLine Del 2155 [hereinafter, “Rahul Sood”].

5. Mr. Kher further submits that, when