K. Bhaskaran v. Sankaran Vaidhyan Balan
Supreme Court of India(1999) 7 SCC 510The Supreme Court identified five places where the cause of action for dishonour arises under S.138: (1) where the cheque was drawn, (2) where it was presented for payment, (3) where it was dishonoured, (4) where the notice of demand was despatched, and (5) where it was received. The court within whose jurisdiction any of these five acts takes place is competent to entertain the complaint. This five-point test was applied widely until it was substantially restricted by Dashrath Rupsingh Rathod in 2014 and then replaced by the 2015 Amendment.