Cheque Bounce ADR & Settlement • Section 147 NI Act September 8, 2026 14 Min Read

Waiving Graded Compounding Costs in Section 138 NI Act: The Damodar S. Prabhu Exception Doctrine in Delhi NCR Courts

Advocate & Legal Consultant • Delhi High Court & District Courts

Strategic Executive Summary

Graded Compounding Matrix Under Damodar Prabhu: The Supreme Court established a structured scale (0% at initial trial stage, 10% in Sessions Court appeal, and 15% before High Court / Supreme Court) payable to the District Legal Services Authority (DLSA) to disincentivize dilatory tactics.
The Critical Para 25 Judicial Escape Hatch: Paragraph 25 of Damodar S. Prabhu v. Sayed Babalal H. explicitly vests criminal courts with discretion to reduce or completely waive compounding costs, provided the court records cogent reasons in writing.
Recognized Grounds for Complete Cost Exemption: Real-world Delhi NCR practice (Saket, Tis Hazari, Patiala House, Rohini) shows that courts grant complete waivers upon showing bona fide indigence/insolvency, acute medical emergencies, senior citizen distress, or mutual compromise initiated at the first available opportunity.
Lok Adalat Settlement Exemption: Under the Supreme Court's mandate in M.P. State Legal Services Authority v. Prateek Jain, settlements arrived at before the National or Special Lok Adalats are fundamentally exempt from the graded cost scale.
Procedural Drafting Requirements: A successful waiver demands a specialized application under Section 147 of the Negotiable Instruments Act read with Section 359 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) backed by unimpeachable financial disclosure affidavits.

Table of Contents

Waiving Graded Compounding Costs in Section 138 NI Act: The Damodar S. Prabhu Exception Doctrine in Delhi NCR Courts - Urban Rights Legal Consultants

When a cheque bounce dispute under Section 138 of the Negotiable Instruments Act, 1881 is amicably resolved at an appellate or revisional stage, the celebratory relief of settlement is frequently overshadowed by the punitive levy of compounding costs mandated by the Supreme Court in Damodar S. Prabhu v. Sayed Babalal H. (2010) 5 SCC 663. For an accused who has liquidated personal assets, borrowed from relatives, or strained family reserves to pay 100% of the cheque amount or settled compensation to the complainant, depositing an additional 10% before the Sessions Court or 15% to 20% before the Delhi High Court payable to the Delhi State Legal Services Authority (DSLSA) can derail the entire settlement. However, trial lawyers frequently overlook the crucial judicial escape hatch embedded in Paragraph 25 of the Damodar Prabhu judgment itself. This comprehensive courtroom guide explains the exact statutory architecture, substantive grounds, and procedural drafting tactics required to secure a total waiver or substantial reduction of graded compounding costs before the District and Sessions Courts of Delhi NCR and the High Court.

1. The Damodar S. Prabhu Graded Cost Matrix & Statutory Genesis

Section 147 of the Negotiable Instruments Act, 1881, inserted via the 2002 Amendment, established a non-obstante statutory mandate: "Notwithstanding anything contained in the Code of Criminal Procedure, 1973, every offence punishable under this Act shall be compoundable." Unlike conventional criminal compounding governed by Section 320 of the Code of Criminal Procedure, 1973 (now corresponding to Section 359 of the Bharatiya Nagarik Suraksha Sanhita, 2023 [BNSS]), Section 147 NI Act contains no restrictive schedule of compoundable offences, nor does it require prior leave of the court at the trial stage if both commercial disputants consent.

However, this unbridled liberty spawned a catastrophic operational bottleneck in India's metropolitan magistrates' courts. Litigants routinely delayed settlement, contested frivolous technicalities across years of magistrate trials, and then approached the Sessions Court in appeal or the High Court in revision under Section 397/401 CrPC (now Section 438/442 BNSS) only after conviction and sentencing, casually tendering the cheque sum to evade imprisonment. To curb this systemic abuse, the Supreme Court of India in Damodar S. Prabhu v. Sayed Babalal H. (2010) 5 SCC 663 exercised its constitutional powers under Article 142 to frame a mandatory graded cost scale for compounding Section 138 offences:

Litigation Stage	Prescribed Compounding Cost Scale	Designated Recipient Fund	Procedural Rationale
Magisterial Trial Court (Up to Notice Framing & Cross-Examination)	0% Cost (Cost-free window)	N/A	Incentivizes immediate dispute resolution at the threshold before judicial hours are consumed.
Trial Court Post-Framing of Notice (After trial has formally commenced)	Discretionary Costs (Nominal / Court Discretion)	District Legal Services Authority (DLSA)	Discourages prolonged defence examination when settlement intentions exist.
Sessions Court (Criminal Appeal against conviction under Sec 374 CrPC / Sec 415 BNSS)	10% of Cheque Amount	District Legal Services Authority (DLSA)	Compensates the public justice delivery system for wasted magisterial trial resources.
High Court / Supreme Court (Criminal Revision under Sec 397/401 CrPC / Sec 438/442 BNSS)	15% of Cheque Amount	State Legal Services Authority (SLSA)	Penalizes dilatory tactics that drag quasi-criminal recovery litigation to constitutional courts.
Belated Applications in Higher Courts (After prolonged evasion or non-appearance)	20% of Cheque Amount	National / State Legal Services Authority	Maximum deterrent levy for obstinate defaulters seeking eleventh-hour bail protection.

Fundamental Judicial Purpose:

In Damodar Prabhu, the Supreme Court explicitly held that Section 138 proceedings are predominantly civil in substance clothed in criminal procedural garb. The graded fee is not a fine payable to the State Treasury, nor is it compensation payable to the complainant; it is a regulatory cost deposited directly to the Legal Services Authority to replenish legal aid funds expended on indigent litigants.

2. The Para 25 Exception: Judicial Discretion to Waive or Reduce Costs

The most consequential paragraph for defence litigators in the entire Damodar Prabhu judgment is Paragraph 25. Far from creating an immutable, mechanical tax on compounding, the Supreme Court expressly recognized that rigid arithmetic mandates could frustrate the primary legislative objective of the NI Act—namely, facilitating voluntary financial settlement. Paragraph 25 reads verbatim:

"25. The graded scale of costs would of course be a deterrent against delayed attempts at compounding... However, we must also make it clear that the imposition of costs by the competent court is discretionary, even though the guidelines indicate the rates. A departure from the said guidelines should be allowed only on recording reasons in writing for such departure. The courts can also consider whether the accused had appeared on the very first date of hearing or whether the conduct of the parties warrants a waiver or modification of costs..."

This discretionary clause has been repeatedly reinforced and expanded by subsequent landmark decisions:

Madhukar v. State of Maharashtra: The Bombay High Court and subsequent Supreme Court observations held that where an appellant is elderly, medically compromised, or has exhausted his entire financial wherewithal to satisfy the substantive debt due to the complainant, saddling him with statutory compounding costs would defeat substantial justice.
K. Subramani v. K. Damodara Naidu (2015) 1 SCC 99: The Supreme Court underscored that appellate courts must balance deterrence against real economic reality. Where compounding is arrived at through mutual goodwill and the accused demonstrates genuine indigence, the court is duty-bound to exercise its Paragraph 25 discretion to waive or drastically reduce the levy.
In Re: Expeditious Trial of Cases under Section 138 of N.I. Act, 1881 (2021) 16 SCC 116: The 5-Judge Constitution Bench affirmed the vitality of compounding under Section 147 while cautioning that magisterial and appellate courts must actively encourage amicable settlement without imposing punitive deterrent hurdles that force indigent debtors into prison sentences.

3. 5 Recognized Grounds for Seeking Full Cost Waiver in Delhi NCR Courts

In the Sessions Courts of Delhi (Tis Hazari, Saket, Patiala House, Rohini, Dwarka) and Gurugram / Faridabad, Sessions Judges do not grant compounding cost exemptions upon a mere verbal plea. Defence counsel must anchor the exemption application upon one or more of five judicially recognized factual anchors:

1. Genuine Penury & Insolvency

The accused has suffered catastrophic business failure, personal insolvency, or loss of livelihood. Where the settled cheque sum was pooled through contributions from close relatives or charitable borrowals, the court will not compel payment of a further 10% or 15% DLSA levy. Supporting documents: Bank freeze orders, ITRs showing nil taxable income, or insolvency notices.

2. Critical Medical Distress & Seniority

Severe debilitating illness (such as cancer, advanced cardiovascular conditions, kidney failure requiring dialysis) or advanced age (senior citizens above 65 years). Courts in Delhi NCR take judicial notice of immense medical expenditures and routinely exercise Paragraph 25 discretion to waive DLSA costs completely.

3. Immediate First-Instance Settlement

Where the accused was prevented from appearing before the trial court due to improper service of summons (e.g. speed post delivered to an obsolete tenancy address) and immediately offered full settlement upon learning of the conviction or upon first appearance in appeal, the appellate court recognizes the absence of contumacious delay and waives costs.

4. Complainant's Active Support for Waiver

In commercial disputes where the complainant confirms under oath that the dishonour stemmed from a bona fide business dispute, that all payments have been cleared in full, and specifically requests the court not to burden the accused with legal aid levies, Sessions Courts routinely record this as a cogent written reason under Paragraph 25.

5. High-Value Cheques & Disproportionate Levy

In commercial cheque bounce cases involving multi-crore transactions (e.g. ₹5 Crores to ₹20 Crores), a rigid 10% to 15% DLSA levy translates into ₹50 Lakhs to ₹3 Crores in compounding costs. Delhi High Court benches consistently hold that imposing such an astronomical fee operates as an unconstitutional penalty, reducing the cost to a nominal fixed token sum (e.g. ₹50,000 to ₹1 Lakh).

4. Appellate Court Realities: Practice Before Sessions Judges at Saket, Tis Hazari & Patiala House

Advocating for a cost waiver before the Additional Sessions Judges (ASJs) in Delhi NCR requires acute procedural awareness. Unlike magistrates who handle dozens of summary trials daily, Sessions Judges adjudicate criminal appeals under Section 374 CrPC (now Section 415 BNSS) and exercise strict oversight over DLSA deposits.

In Saket Courts (South and South-East Districts) and Tis Hazari (Central and West), the standard practice of Sessions Judges upon receiving a joint compounding application is to direct counsel to produce the formal receipt of DLSA deposit before passing the final acquittal order. If the accused simply states that he has no funds, the court may refuse to record the compounding, suspend the sentence conditionally, or dismiss the appeal.

To successfully secure an order of complete waiver, counsel must follow this courtroom tactical protocol:

Do Not File an Oral Plea: Never raise cost waiver casually at the bar. Always file a formal, paginated, verified application under Section 147 NI Act read with Paragraph 25 of Damodar S. Prabhu and Section 359 BNSS.
Incorporate the Complainant's No-Objection: Ensure that the bilateral settlement agreement or compromise deed contains an explicit clause: "The Complainant has received the agreed sum in full and final satisfaction and has no objection if the Hon'ble Court completely waives the graded compounding costs in view of the Appellant's severe financial crisis."
Tender contemporaneous Financial Proof: Attach bank statements showing marginal balances, medical prescriptions, or proof of sale of residential or commercial property utilized to fund the complainant's settlement.
Propose a Nominal Token Contribution: If the Sessions Judge is hesitant to grant an outright 100% waiver, counsel should proactively propose a nominal, token sum (e.g. ₹10,000 or ₹25,000) payable to the Delhi State Legal Services Authority or the Bar Association Welfare Fund, enabling the judge to record substantial compliance with the spirit of Damodar Prabhu.

5. Lok Adalat vs. Regular Court Compounding: The Prateek Jain Doctrine

One of the most effective strategies to legally bypass the Damodar Prabhu graded cost scale altogether is routing the settlement through the National Lok Adalat or Special Lok Adalats organized periodically by the District Legal Services Authorities.

In M.P. State Legal Services Authority v. Prateek Jain (2014) 10 SCC 690, the Supreme Court delivered a decisive verdict on whether the graded cost scale applies to settlements finalized before the Lok Adalat. The Court noted that the primary mission of the Legal Services Authorities Act, 1987 is to promote alternative dispute resolution and unclog regular courts. Imposing a 10% or 15% compounding levy on a poor debtor who settles his matter before the Lok Adalat would directly subvert the purpose of the Lok Adalat system.

Crucial Takeaways from Prateek Jain (2014):

Total Exemption in Lok Adalat: Where a Section 138 matter is compounded before a Lok Adalat at any stage (whether trial, appeal, or revision), the graded costs prescribed in Damodar Prabhu are NOT mandatory.
Lok Adalat Discretion: The Lok Adalat bench possesses untrammeled discretion to waive the compounding cost in its entirety or impose a negligible, nominal token fee depending on the circumstances.
Automatic Refund of Court Fees: Settlements before the Lok Adalat carry the additional statutory benefit of 100% refund of court fees paid on appeal or complaint under Section 16 of the Court Fees Act, 1870.

6. Courtroom Ready Draft: Application for Complete Exemption of Compounding Cost

Below is a field-tested, comprehensive application template drafted according to the practice directions of the District and Sessions Courts of Delhi (Saket, Tis Hazari, Patiala House, Rohini, Dwarka):

IN THE COURT OF PRINCIPAL DISTRICT & SESSIONS JUDGE / ADDITIONAL SESSIONS JUDGE
                        AT _______________ DISTRICT, DELHI

                     CRIMINAL APPEAL NO. ________ OF 2026
                     IN THE MATTER OF:
____________________                                        ...APPELLANT / CONVICT
                                    VERSUS
____________________                                        ...RESPONDENT / COMPLAINANT
AND
STATE (NCT OF DELHI)                                        ...RESPONDENT NO. 2

APPLICATION UNDER SECTION 147 OF THE NEGOTIABLE INSTRUMENTS ACT, 1881 READ WITH 
PARAGRAPH 25 OF THE HON'BLE SUPREME COURT BENCHMARK IN 'DAMODAR S. PRABHU V. SAYED 
BABALAL H.' (2010) 5 SCC 663 AND SECTION 359 OF THE BHARATIYA NAGARIK SURAKSHA 
SANHITA, 2023 (BNSS) SEEKING COMPLETE WAIVER / EXEMPTION OF GRADED COMPOUNDING COSTS 
PAYABLE TO THE DISTRICT LEGAL SERVICES AUTHORITY (DLSA).

MOST RESPECTFULLY SHOWETH:

1. That the Appellant has preferred the captioned Criminal Appeal challenging the 
   impugned Judgment of Conviction dated __.__.2026 and Order on Sentence dated __.__.2026 
   passed by the Court of Ld. Metropolitan Magistrate (NI Act Digital Court), Delhi in 
   CC No. _______ of 2024, convicting the Appellant under Section 138 NI Act and sentencing 
   him to simple imprisonment of 6 months along with a fine/compensation of Rs. ________/-.

2. That during the pendency of the captioned appeal, through the intervention of well-wishers 
   and counsel, the Appellant and the Respondent No. 1 (Complainant) have amicably settled 
   all their disputes in toto vide a written Settlement Agreement / Compromise Deed dated 
   __.__.2026. A true copy of the said Settlement Agreement is annexed herewith as ANNEXURE A-1.

3. That the Appellant has paid the entire settled sum of Rs. __________/- (Rupees ________________ 
   Only) to the Respondent No. 1 vide Demand Draft No. ________ dated __.__.2026 drawn on 
   ________________ Bank, which has been duly encashed and acknowledged by Respondent No. 1 
   in full and final satisfaction of all claims.

4. That in terms of Section 147 of the Negotiable Instruments Act, 1881, the offence under 
   Section 138 NI Act is compoundable at any stage of proceedings. The Respondent No. 1 has 
   tendered his categorical consent and affidavit supporting the compounding of the offence.

5. That the Appellant most humbly seeks complete waiver and exemption of the graded 10% 
   compounding cost prescribed in 'Damodar S. Prabhu v. Sayed Babalal H. (2010) 5 SCC 663' 
   payable to the District Legal Services Authority (DLSA) on the following exceptional grounds 
   squarely covered under Paragraph 25 of the said judgment:

   a. SEVERE ECONOMIC PENURY & BORROWED FUNDS: The Appellant suffered catastrophic commercial 
      ruin during business operations, resulting in complete cessation of his trade. The entire 
      settlement amount of Rs. _________/- paid to the Complainant was assembled by taking loans 
      from close family relatives and mortgaging personal household belongings. The Appellant's 
      bank statements (annexed as ANNEXURE A-2) demonstrate zero disposable balance.

   b. GRAVE MEDICAL EMERGENCY: The Appellant is aged ___ years and is undergoing prolonged 
      treatment for _____________________ at ________________ Hospital, incurring prohibitive 
      recurring expenses. Relevant medical records and discharge summaries are annexed as ANNEXURE A-3.

   c. ABSENCE OF DILATORY CONDUCT: The Appellant did not deliberately protract the trial; the 
      conviction was recorded in his absence due to non-receipt of summons at his previous address. 
      The Appellant approached this Hon'ble Appellate Court at the earliest available opportunity 
      and settled the dispute without consuming precious appellate trial time.

   d. COMPLAINANT'S CONCURRENCE: The Respondent No. 1 (Complainant) has specifically stated in 
      his affidavit that he does not desire the Appellant to be subjected to any further financial 
      hardship by way of DLSA compounding costs.

6. That under Paragraph 25 of 'Damodar S. Prabhu' (supra), the Hon'ble Supreme Court has held 
   that the imposition of costs is discretionary and the appellate court is fully empowered 
   to waive or reduce costs upon recording cogent reasons in writing.

7. That if the graded compounding cost of Rs. ________/- (being 10% of the cheque amount) is 
   imposed, the Appellant will be utterly incapable of paying the same and will face 
   unwarranted incarceration, thereby defeating the benevolent objective of Section 147 NI Act.

PRAYER:
Wherefore, in the interest of justice and equity, it is most respectfully prayed that 
this Hon'ble Court may graciously be pleased to:
(a) Allow the present application and record the compounding of the offence under Section 138 
    of the Negotiable Instruments Act between the Appellant and Respondent No. 1;
(b) Completely waive and exempt the Appellant from payment of the 10% graded compounding cost 
    payable to the District Legal Services Authority (DLSA) in terms of Paragraph 25 of the 
    landmark judgment in 'Damodar S. Prabhu v. Sayed Babalal H.';
(c) Set aside the impugned Judgment of Conviction and Order on Sentence dated __.__.2026 passed 
    by the Ld. Trial Court, and acquit the Appellant of all charges under Section 138 NI Act; and
(d) Pass any other or further order(s) as this Hon'ble Court may deem fit and proper.

APPELLANT                                                  THROUGH COUNSEL
DATED: __.__.2026                                          ADVOCATE FOR THE APPELLANT
PLACE: NEW DELHI                                           DELHI HIGH COURT & DISTRICT COURTS
  

7. Evidentiary Protocol: Proving Indigence, Medical Distress & Liquidity Crisis

Judges in Delhi NCR criminal courts are experienced in identifying artificial pleas of poverty. To secure an exemption order that withstands scrutiny, counsel must tender certified documentary exhibits:

Indispensable Evidentiary Exhibits Checklist

Income Tax Returns (Past 3 Consecutive Years): Demonstrating that the accused's gross total income is below the basic exemption limit or has plunged significantly following business collapse.
Bank Account Statements (Personal & Firm): Showing negligible credit balances, persistent negative liquidity, or active attachment orders under SARFAESI Act or Section 461 BNSS.
Government Hospital / Empanelled Healthcare Certificates: Diagnostic reports, ongoing chemotherapy / dialysis prescriptions, or disability identity cards issued under the Rights of Persons with Disabilities Act, 2016.
Affidavits from Third-Party Financiers / Relatives: Affidavits affirming that the settled cheque amount was assembled through familial contributions solely to prevent the accused from enduring custodial sentence.
Complainant's Unconditional No-Objection Affidavit: Stating clearly that the debt has been liquidated amicably and supporting the waiver application in the interest of mutual industrial harmony.

8. Step-by-Step Strategic Roadmap for Accused Seeking Compounding Without Costs

An accused party seeking to compound an appeal or revision without paying the 10% to 15% compounding levy should execute the following chronological roadmap:

Chronological Courtroom Roadmap

Step 1: Execute a Written Settlement Agreement: Incorporate unambiguous terms regarding full settlement, total withdrawal of claims, and an express clause recording the Complainant's consent to cost waiver.
Step 2: Clear 100% of the Settlement Sum First: Never seek a cost waiver while part of the settled principal remains unpaid. Deposit or hand over the Demand Draft in court.
Step 3: Move Section 147 Application with Para 25 Prayer: File the formal written application supported by financial and medical exhibits before the Sessions Judge or High Court.
Step 4: Record Statements of Parties Under Oath: Both the Complainant and Accused appear in court; the Complainant confirms receipt of money and states on oath that he does not wish costs to be imposed.
Step 5: Assist the Court in Recording Written Reasons: Provide draft points to the judge highlighting indigence, lack of contumacious conduct, and commercial resolution to ensure compliance with Paragraph 25's statutory mandate.

Statutory Authorities & Legal References

Negotiable Instruments Act, 1881 (Section 138, Section 147 inserted by Act 55 of 2002).
Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) [Section 359 (Compounding), Section 415 (Appeals), Section 438/442 (Revisions)].
Code of Criminal Procedure, 1973 [Legacy Section 320, Section 374, Section 397/401].
Damodar S. Prabhu v. Sayed Babalal H. (2010) 5 SCC 663 (3-Judge Bench establishing graded compounding cost scale & Para 25 judicial exception).
M.P. State Legal Services Authority v. Prateek Jain (2014) 10 SCC 690 (Exemption of Lok Adalat settlements from graded compounding cost scale).
K. Subramani v. K. Damodara Naidu (2015) 1 SCC 99 (Judicial discretion to reduce or waive compounding costs on genuine economic distress).
In Re: Expeditious Trial of Cases under Section 138 of N.I. Act, 1881 (2021) 16 SCC 116 (5-Judge Constitution Bench).
Legal Services Authorities Act, 1987 (Functions and allocation of DLSA / SLSA victim compensation and legal aid funds).

Disclaimer: This article is published strictly for academic and educational purposes under the Advocates Act, 1961. It does not constitute formal legal advice, solicitation, or advertisement under Rule 36 of the Bar Council of India Rules, nor does it create an advocate-client relationship. For case-specific legal counsel, readers should consult an independent advocate.

Is paying the 10% or 15% compounding cost to DLSA strictly mandatory under Damodar Prabhu?

No. While Damodar S. Prabhu prescribes 10% in the Sessions Court and 15% in the High Court as general benchmarks, Paragraph 25 of the judgment explicitly vests courts with judicial discretion to reduce or completely waive costs upon recording reasons in writing. Genuine indigence, critical medical conditions, or immediate settlement upon appearance are recognized grounds for total waiver.

Can a Metropolitan Magistrate at the trial court stage impose compounding costs under Section 147?

If the accused settles the dispute at the initial summons stage before trial commences, compounding is completely cost-free (0%). If the matter is settled after the framing of notice under Section 251 CrPC / Section 274 BNSS, the Magistrate has discretion to impose nominal costs, but usually waives them if both parties report full satisfaction.

Does the graded cost scale apply if the matter is settled before the National Lok Adalat?

No. Under the Supreme Court ruling in M.P. State Legal Services Authority v. Prateek Jain (2014) 10 SCC 690, settlements reached before the Lok Adalat are exempt from the graded cost scale. The Lok Adalat bench has full discretion to completely waive costs to encourage alternative dispute resolution.

Where does the compounding cost go once deposited by the accused?

The costs are deposited with the District Legal Services Authority (DLSA) or the State Legal Services Authority (SLSA). These funds do not go to the complainant or the court treasury; they are statutorily earmarked to provide free legal aid to underprivileged litigants and victims.

Can the complainant consent to waive the DLSA compounding fee on behalf of the court?

The complainant cannot unilaterally waive the fee because the cost is payable to the State Legal Services Authority, not to the complainant. However, the complainant's express no-objection and endorsement in an affidavit serve as powerful corroborative grounds for the Judge to exercise discretion under Paragraph 25 to waive the levy.

What happens if an accused settles with the complainant but cannot pay the 10% DLSA cost?

If the court does not grant a waiver and the accused fails to deposit the DLSA cost, the appellate court cannot formally record the acquittal under Section 147 NI Act. The court may dismiss the compounding application or grant time to deposit. This is why a formal application under Paragraph 25 supported by financial evidence must be filed prior to the final hearing.

How do Delhi NCR courts treat compounding costs in high-value commercial cheques of ₹5 Crores or more?

In multi-crore commercial disputes, a rigid 10% or 15% levy would amount to ₹50 Lakhs to ₹1 Crore or more, which courts recognize as disproportionate and punitive. High Courts and Sessions Courts in Delhi routinely cap or reduce such fees to a nominal token amount (such as ₹50,000 to ₹1 Lakh) payable to DLSA.