The High Court of Delhi, in a judgment delivered on October 8, 2025, has quashed two criminal complaints filed under Section 138 of the Negotiable Instruments (NI) Act, holding that the proceedings were not maintainable as the complainant company had been “struck-off” the Register of Companies and dissolved before the complaints were instituted.

Justice Arun Monga , in case bearing CRL.M.C. 7534/2023 and CRL.M.C. 7559/2023, allowed the petitions filed by Mr. Krishan Lal Gulati and another, who were directors of the accused company. The court set aside a 2022 order by aMagisterial court that had dismissed the petitioners’ applications and allowed the cheque bounce cases to proceed.

Background of the Case

The matter originated from two criminal complaints (CC No. 2619/2020 and CC No. 473

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