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M.S. Narayana Menon @ Mani vs State Of Kerala & Anr on 4 July, 2006

In this regard, the Law laid down by the Hon'ble Apex Court in M.S. Narayana Menon @ Mani v. State of Kerala and another, 2006 (6) SCC 39, can be taken as a precedent. The Hon'ble Apex Court in the said Judgment cited supra has stated that the presumption under Sections 118 and 139 shall be with the standard of proof of preponderance of probability only. The relevant portions of the said Judgment are extracted hereunder:
Supreme Court of India Cites 24 - Cited by 4105 - S B Sinha - Full Document

Rangappa vs Sri Mohan on 7 May, 2010

"26. In light of these extracts, we are in agreement with the Respondent Claimant that the presumption mandated by Section 139 of the Act does indeed include the existence of a legally enforceable debt or liability. To that extent, the impugned observation in Krishna Janardhan Bhat, 2008 (4) SCC 54 : 2008 (2) SCC (Cri) 166, may not be correct. However, this does not in any way cast doubt on the correctness of the decision in that case since it was based on the specific facts and circumstances therein. As noted in the citations, this is of course in the nature of a rebuttable presumption and it is open to the Accused to raise a defence wherein the existence of a legally enforceable debt or liability can be contested. However, there can be no doubt that there is an initial presumption, which favours the Complainant.
Supreme Court of India Cites 11 - Cited by 9567 - K G Balakrishnan - Full Document
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