Bengaluru: In a significant ruling, the Karnataka High Court held that the same accused cannot demand a single trial for two separate complaints filed by different complainants under distinct circumstances. “A complainant is the master of his prosecution. His interests and rights also have to be protected,” Justice Shivashankar Amarannavar declared whilst rejecting a petition from Puttanagouda, a farmer from Kadashettihalli village in Haveri district’s Hanagal taluk.
Two cheque bounce cases were registered against Puttanagouda in 2021, pending before the Senior Civil Judge and JMFC, Hangal. The complaints were separately filed by Kubergouda and Channabasappa. Puttanagouda sought a single trial, citing Sections 219 and 220 of the Criminal Procedure Code, arguing that the alleged offences occurred within a year. The magistrate rejected this request, citing different circumstances. The sessions court subsequently dismissed his appeal on November 7, 2022.

In his high court petition challenging the sessions court order, Puttanagouda contended that Section 219 of CrPC allows for a single trial of up to three similar offences committed within twelve months, regardless of whether they involve the same complainant. Justice Amarannavar disagreed, clarifying that Section 219 CrPC does not permit joint trials of separate Section 138 of Negotiable Instruments Act cases filed by different complainants with distinct causes of action, despite having the same accused.
The judge elaborated that Section 220 of CrPC also failed to support the petitioner’s case. The court noted that separate examination of complainants, witnesses, and documents was necessary for each case, requiring individual evaluation of merits, thereby dismissing the petition.