Alex Mathew vs Philip Philip on 20 March, 1973
"The cases referred to above clearly disclose conflict of judicial opinion on the question of onus where it is found that the consideration originally pleaded has been found to be false. I am, however, bound by the decisions of this Court which are in consonance with the view taken by the Lahore High Court and following those decisions. I am bound to hold that once the defendant bad shown that the cash consideration which was originally pleaded for the Hundi did not pass, he had discharged the onus which lay upon him of proving the lack of consideration in view of the presumption that is attached to the Hundi as a negotiable instrument under Section 118 of the Negotiable Instruments Act and the onus then shifted
upon the plaintiff to prove that there was consideration."