Showing posts with label closed bank account. Show all posts
Showing posts with label closed bank account. Show all posts

Friday, 8 May 2015

Whether Offence U/S 138 of NI Act is made out when cheque is returned with endorsement that account is closed?

Lastly, we would refer to the decision by a Three-Judge Bench of this Court in the case of Modi Cements Ltd. Vs. Kuchil Kumar Nandi (1998) 3 S.C.C. 249 dealing with a similar contention and interpreting Section 138 of the Act. In that case, the Court referred to the earlier decisions in the case of Electronics Trade and Technology Development Corporation (1996) 2 SCC 739 and K.K. Siddharthan Vs. T.P. Praveena Chandran (1996) 6 S.C.C. 369 and agreed that the legal proposition enunciated in the aforesaid decisions to effect that if the cheque is dishonoured, because of stop payment instruction to the bank, Section 138 would get attracted. It also amounts to dishonour of the cheque within the meaning of Section 138 when it is returned by the bank with the endorsement like (I) in this case, referred to the drawer (ii) instructions for stoppage of payment and stamped (iii) exceeds agreement. The Court observed that the object of bringing Section 138 on statute appears to be to inculcate faith in the efficacy of banking operations and credibility in transaction in business on negotiable instruments and to promote the efficacy of banking operations and to ensure credibility in transacting business through cheques. Thereafter, the Court disagreed with other views expressed in aforesaid two cases and held that once the cheque is issued by the drawer a presumption under section 139 must follow and merely because the drawer issues a notice to the drawee or to the bank for stoppage of the payment it will not preclude an action under Section 138 of the Act by the drawee or the holder of a cheque in due course. The Court further held that it will make section 138 a dead letter if the contention that by giving instruction to the Bank to stop payment immediately after issuing a cheque against the debt or liability, the drawer can easily get rid of the penal consequences notwithstanding the fact that deemed offence was committed. Finally, the Court held that Section 138 of the Act gets attracted only when the cheque is dishonoured. In view of the aforesaid discussion we are of the opinion that even though Section 138 is a penal statute, it is the duty of the Court to interpret it consistent with the legislative intent and purpose so as to suppress the mischief and advance the remedy. As stated above, Section 138 of the Act has created a contractual breach as an offence and the legislative purpose is to promote efficacy of banking and of ensuring that in commercial or contractual transactions cheques are not dishonoured and credibility in transacting business through cheques is maintained. The above interpretation would be in accordance with the principle of interpretation quoted above brush away the cobweb varnish, and show the transactions in their true light (Wilmot C. J.) or (by Maxwell) to carry out effectively the breach of the statute, it must be so construed as to defeat all attempts to do, or avoid doing, to an indirect or circuitous manner that it has prohibited. Hence, when the cheque is returned by a bank with an endorsement account closed, it would amount to returning the cheque unpaid because the amount of money standing to the credit of that account is insufficient to honour the cheque as envisaged in Section 138 of the Act.
Supreme Court of India
Nepc Micon Limited And Others vs Magma Leasing Limited on 29 April, 1999
Bench: K.T.Thoms, M.B.Shah
Citation;AIR1999SC1952,1999(4)ALLMR(SC)367[1999]96CompCas822(SC), 1999CriLJ2883,
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Whether offence of dishonour of cheque is made out if accused issued cheque after closure of his bank account?

 When the facts and circumstances of the present case are examined in the light of observations made in the aforesaid extract, I am of the considered opinion that even if the petitioner has issued a cheque on an account being maintained by him and the account was closed by him prior to issuance of the cheque, the net effect is that there was no money in the account on which the cheque was drawn and as a result, the cheque got dishonoured for want of funds to honour the cheque in that account attracting mischief of Section 138 of the Act. The petitioner in the circumstances of the present case may also be guilty of committing another offence for issuance of cheque from an account which already stood closed. Keeping in view conduct of the petitioner, he otherwise does not entitle himself to seek indulgence of this court in exercise of inherent jurisdiction under Section482 Cr.P.C.
In the High Court of Punjab and Haryana at Chandigarh
CRM-M-33763 of 2010
Date of Decision:23.7.2014
Sandeep Mehra alias Babl
V
Chander Parkash Madan

Coram: Hon’ble Mrs. Justice Rekha Mittal
Citation;2015 ALLMR(CRI)JOURNAL231
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