The Supreme Court, in Vishnu Dutt Sharma v. Daya Sapra [(2009) 13 SCC 729], held that there is no legal bar to the simultaneous continuation of civil and criminal proceedings arising out of the same cheque transaction or cause of action. The pendency of one proceeding does not preclude or affect the maintainability of the other, as both remedies are distinct in their nature, scope, and object.
The legal position has been consistently reaffirmed by a catena of decisions of the Hon’ble Supreme Court, including P. Swaroopa Rani v. M. Hari Narayana @ Hari Babu [(2008) 5 SCC 765], D. Purushotama Reddy and Another v. K. Sateesh [(2008) 8 SCC 505], and State of Rajasthan v. Kalyan Sundaram Cement Industries Ltd [(1996) 3 SCC 87].
These decisions conclusively establish that civil and criminal proceedings arising from the same transaction or cause of action may proceed simultaneously and independently, as they serve different legal purposes and are governed by different standards of proof.