Dear Mr. Arun, Please appreciate the circumstances in which the decision in Meters and Instruments Private Limited and Another Vs. Kanchan Mehta [(2018) 1 scc 560) was given.
In the said case, when the matter came up before the Supreme Court, notice was issued to consider the question as to how proceedings for an offence under Sec. 138 of the N.I. Act can be regulared WHERE THE ACCUSED IS WILLING TO DEPOSIT THE CHEQUE AMOUNT. Whether in such a case, the proceedings can be closed or exemption granted from personal appearance or any other order can be passed.
After completely examining the matter, ultimately the Hon'ble Supreme Court has said as under:
"20. In every complaint under Section 138 of the Act, it may be desirable that the complainant gives his bank account number and if possible e-mail ID of the accused. If e-mail ID is available with the bank where the accused has an account, such bank, on being required, should furnish such e-mail ID to the payee of the cheque. In every summons issued to the accused, it may be indicated that if the accused deposits the specified amount, which should be assessed by the court having regard to the cheque amount and interest/cost, by a specified date, the accused need not appear unless required and proceedings may be closed subject to any valid objection of the complainant. If the accused complies with such summons and informs the court and the complainant by e-mail, the court can ascertain the objection, if any, of the complainant and close the proceedings unless it becomes necessary to proceed with the case. In such a situation, the accused's presence can be required, unless the presence is otherwise exempted subject to such conditions as may be considered appropriate. The accused, who wants to contest the case, must be required to disclose specific defence for such contest. It is open to the court to ask specific questions to the accused at that stage. In case the trial is to proceed, it will be open to the court to explore the possibility of settlement. It will also be open to the court to consider the provisions of plea bargaining. Subject to this, the trial can be on day-to-day basis and endeavour must be to conclude it within six months. The guilty must be punished at the earliest as per law and the one who obeys the law need not be held up in proceedings for long unnecessarily."
The Supreme Court also said"
"21. It will be open to the High Courts to consider and lay down category of cases where proceedings or part thereof can be conducted online by designated courts or otherwise. The High Courts may also consider issuing any further updated directions for dealing with Section 138 cases in the light of judgments of this Court. "
So it is against this backdrop, the said Circular mentioned by you might have been issued. But the paragraph 3 in the Circular will apply only to those accuseds who are willing to deposit the cheque amount and get the case closed. That paragraph will not apply in case the Accused wants to contest the case.