Whether the court can conduct S 202 CRPC proceeding under dishonour of cheque case on the basis of documents only?

[Educator]

We may note here that as far as complaints underSection 138 of the NI Act are concerned, this Court inSuo Motu Writ Petition (Criminal)No.2 of 2020 in the caseof "In Re : Expeditious Trial of Cases Under Section 138of N.I.Act, 18811" has laid down the guidelines. Inclause (3) of paragraph 24 of the said decision, theConstitution Bench has directed as under:"3) For the conduct of inquiry under