Surinder Singh Deswal v. Virender Gandhi
Supreme Court of India(2019) 17 SCC 1Bench: J. Ashok Bhushan, J. K.M. Joseph
The Supreme Court held that the statutory minimum of 20% under Section 148 NI Act is a floor, not a range with downward discretion. The appellate court cannot reduce the deposit below 20% on any ground, including financial hardship of the accused. The word "minimum" in Section 148 has a specific meaning — it is the lowest permissible amount, not a starting point for judicial downward revision. The deposit requirement operates as a filter to ensure that only genuine appeals are prosecuted while protecting the complainant's right to some immediate compensation. The High Court order directing only 15% was set aside.