In Brief
The Supreme Court held that a Trust is not a separate legal entity or juristic person and therefore cannot be made an accused in a criminal complaint under the Negotiable Instruments Act. When a cheque is dishonoured, the complaint is maintainable only against the Trustee who signed it, without requiring the Trust to be a party. Trusts operate exclusively through Trustees, who bear all legal responsibility for acts done on behalf of the Trust. The Court rejected the view that Trusts should be treated like companies under the NI Act, clarifying that only Trustees can sue or be sued to protect trust property, as established by the Indian Trusts Act, 1882.
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