Jai Balaji Industries Ltd. v. M/s HEG Ltd.; 2025 INSC 1362 - Cheque Bounce Case - Jurisdiction Of Courts

Negotiable Instruments Act 1881 - Section 138,142(2)(a) -The jurisdiction to try a complaint filed under Section 138 in respect of a cheque delivered for collection through an account, i.e., an account payee cheque, is vested in the court within whose local jurisdiction the branch of the bank in which the payee maintains the account, i.e., the payee’s home branch, is situated.  (Para 76) Even if the cheque is delivered to a branch other than the home branch for commercial convenience, it shall be considered to have been delivered to the home branch for the legal purpose of determining jurisdiction. (Para 72) If the jurisdiction is to be decided on the basis of the place where the cheque was delivered to the bank of the payee, the same would lead to conferring unbridled power to the payee in deciding jurisdiction which may be misused for the purposes of forum shopping. (Para 57) [Held that Yogesh Upadhyay v. Atlanta Ltd., (2023) 19 SCC 404 is per incuriam] [Context: In this case, cheque was drawn by the accused on the State Bank of Bikaner and Jaipur, Kolkata and the same was deposited by the complainant in its account maintained with the State Bank of India, Bhopal branch - The complaint was filed in the court of the Metropolitan Magistrate, Kolkata - SC held that the MM, Kolkata does not have jurisdiction to try the case.]

Negotiable Instruments Act 1881 - Section 142(2)(b)- Even if a cheque is dishonoured elsewhere, the jurisdiction for trial of the complaint under Section 138 would lie with the court within whose local jurisdiction the branch of the drawee bank in which the drawer maintains the account, is situated. (Para 55)

Interpretation of Statutes - No value can be attached to the language adopted in the Statement of Objects and Reasons for the purpose of discerning the true meaning and effect of a substantive provision occurring in the statute book. (Para 66)