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In M/s Meters and Instrument Pvt. Ltd. V Kanchan Mehta, it was contended by Honorable Supreme Court that an accused in a case under Section 138 of Negotiable Instruments Act can be discharged even without the consent of the complainant if the Court is satisfied that the complainant has been duly compensated. It was also held that the normal role of criminal law that composition of offence is possible only with the consent of complainant/victim is not applicable for cases under Sec.138 of NI Act. This was because the offence under Section 138 was ‘primarily a civil wrong’.