1. Challenging the above-mentioned judgment passed by the trial Court, whereby the petitioner was convicted and sentenced under §138 of the Negotiable Instruments Act, 1881, which was affirmed by the Sessions Court, the convict has approached this Court by filing the present criminal revision petition.

2. Ld. Counsel for the petitioner had submitted that petitioner has deposited the entire compensation amount in compliance with the order dated May 13, 2022, passed by the Court of Judicial Magistrate, Ist Class, Sonipat, pursuant to which his sentence was suspended by this Court vide order dated May 18, 2026 passed in CRM-20499-2026, and that he would confine his submissions for the reduction of sentence to that which the convict has already undergone.

3. However, Ld. Counsel for the petitioner further submits that the complainant has passed away, and the convict/petitioner has no knowledge about the whereabouts of the legal representatives of the complainant.

4. Since the Ld. Counsel for the petitioner has confined his prayer to seeking a reduction of the sentence to the period already undergone; therefore, in the light of the compensation amount being deposited in full by him, this Court is not called upon to examine the correctness or otherwise of the conviction. Accordingly, the scope of the present petition before this Court is limited to the reduction of the sentence.

5. In Sardar Syedna Taher Saifuddin Saheb v. State of Bombay [1958] 1 SCR 1010; 1957-INSC-108, Nov 27, 1957, a five-judge Bench of the Hon’ble Supreme Court holds,

Pending the appeal, the plaintiff died on March 11, 1953, and his daughter applied on May 22, 1953, to be substituted in his place. But eventually she did not press the application, and that was dismissed on October 5, 1953. In this Court by an order dated November 21, 1955, the cause title was amended by deleting the name of the plaintiff. Thus, the only parties who are now before the Court are the defendant and the State of Bombay. The question is whether in the events which have happened, the appeal can proceed. We are of opinion that it cannot. It should be remembered in this connection that no decree had been passed in the suit. Only a finding has been given on a preliminary point, and it is that finding that has been the subject of appeal to the High Court of Bombay and thereafter to this Court. There are other issues still to be tried, and the action is thus undertermined. Now, the claim with which the plaintiff came to Court was that he was wrongly excommunicated, and that was an action personal to him. On the principle, actio personalis moritur cum persona when he died the suit should abate. As a matter of fact, his legal representative applied to be brought on record, but the application was not pressed. The result is that the suit has abated. This would ordinarily entail the dismissal of this appeal. Mr. N. C. Chatterjee for the appellant argues that as the State of Bombay had been impleaded as a party, and that as the decision on the question of the vires of the Act had been given in its presence, the appellant is entitled to continue the appeal against the State without reference to the plaintiff……Here, the action itself has abated, and there can be no question of an appeal in relation thereto, as an appeal is only a continuation of the suit, and there can be no question of continuing what does not exist.

6. In Amarjit Singh Kalra (Dead) By LRs v. Pramod Gupta (Dead) By LRs [2002] SUPP 5 SCR 350; 2002-INSC-541, Dec 12, 2002, a Constitutional Bench of five Judges of the Hon’ble Supreme Court observes,

[pg376][F-G] Laws of procedure are meant to regulate effectively, assist and aid the object of doing substantial and real justice and not to foreclose even an adjudication on merits of substantial rights of citizen under personal, property and other laws. Procedure has always been viewed as the handmaid of justice and not meant to hamper the cause of justice or sanctify miscarriage of jus