Case Synopsis

Jai Balaji Industries Ltd. & Ors. vs. M/s HEG Ltd. (2025 INSC 1362)

Synopsis: The Supreme Court delivered a definitive ruling to settle the contentious issue of territorial jurisdiction in cheque dishonour cases. It authoritatively held that for account payee cheques, the exclusive jurisdiction rests with the court where the payee's bank account is fundamentally maintained (the "home branch"), irrespective of the branch where the cheque was physically deposited. This interpretation, anchored in the deeming fiction of the 2015 Amendment, curtails forum shopping and establishes legal certainty. Notwithstanding this finding, the Court, in the interest of justice, transferred the specific case back to its original venue as the trial there had substantially progressed.

1. Heading of the Judgment

Case Title: Jai Balaji Industries Ltd. & Ors. vs. M/s HEG Ltd.
Citation: 2025 INSC 1362
Court: Supreme Court of India
Bench: Justice J.B. Pardiwala and Justice R. Mahadevan
Jurisdiction: Criminal Original Jurisdiction (Transfer Petitions)

2. Related Laws and Sections

This judgment primarily interprets and clarifies the territorial jurisdiction for trying offences under Section 138 of the Negotiable Instruments Act, 1881 (the "NI Act"). The key statutory provisions discussed are:

• Section 138 of the NI Act: Defines the offence of dishonour of a cheque.

• Section 142 of the NI Act: Pertains to the cognizance of offences. The judgment focuses extensively on Section 142(2)

• Section 142A of the NI

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