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Supreme Court of India 2025-11-28 allowed

Jai Balaji Industries Ltd. and Ors vs M/s. HEG Ltd

Bench: 2 — J.B. Pardiwala, R. Mahadevan

In Brief

A cheque dishonour case turned on whether disputes under Section 138 of the Negotiable Instruments Act must be tried where the cheque was deposited or where the drawer's account is held. The Supreme Court held that for account-payee cheques, jurisdiction lies exclusively at the place where the payee maintains their bank account (home-branch), not where the cheque was deposited or dishonoured. This special rule, introduced by the 2015 Amendment, creates a legal fiction that deems any branch deposit as delivery to the home-branch. While the Kolkata court initially lacked jurisdiction, the Court allowed the case to remain there since trial had already progressed, balancing procedural fairness with the strict jurisdictional principle established.

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Negotiable Instruments Act Criminal Procedure Territorial Jurisdiction Cheque Dishonour Account-Payee Cheque Statutory Interpretation Transfer of Cases

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