Gujarat High Court Criminal Manual (subordinate court practice), 1977
Section 65, Indian Penal Code, provides for sentence of imprisonment in default of fine. The accused persons should not be awarded term of imprisonment in default of payment of fine in excess of the maximum limit prescribed under the Code. The imprisonment in default of payment of fine should not exceed 1/4 of the term of the imprisonment which is maximum fixed for the offence, if the offence is punishable with the imprisonment as well as with the fine.