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Rangappa vs Sri Mohan on 7 May, 2010

40. The decision in Rohitbhai Jivanlal Patel's case (referred supra) will not help the complainant's case and evidence. Hon'ble Supreme Court has referred to its earlier decision Rangappa's case (supra) and summarized the principles regarding presumption under Section 118 and 139 of the N.I.Act and also referred the decision of Kumar Exports vs. Sharma 60 Carpets reported in (2009) 2 SCC 513. It is evident from the principles stated in the said decision that initial presumption is drawn, the factors relating to the want of documentary evidence in the form of receipts or accounts or want of evidence as regards source of funds are not of relevant consideration while examining as to whether the accused has been able to rebut the presumption or not. But in view of factual matrix of this case which are peculiar facts, evidence and circumstances of this case, the nature of the admission made by the complainant and defence evidence of accused, the said principle has no application to this case. The Hon'ble Supreme Court at para-16 clearly held that the word relating to the preponderance of probabilities that the accused has to bring on record such facts and such circumstances which may lead the Court to conclude that either that the consideration did not exist or that its non-existence was so probable that 61 a prudent man would, under the circumstances of the case, act upon the plea that the consideration did not exist and mere denial of the case will not be sufficient to discharge the burden. But here if the evidence of complainant and accused are considered it is evident that the accused has discharged the onus on him. But complainant failed to discharge onus shifted on him.
Supreme Court of India Cites 11 - Cited by 9567 - K G Balakrishnan - Full Document

Bir Singh vs Mukesh Kumar on 6 February, 2019

Again the Hon'ble Supreme Court reiterated the 62 principles regarding presumption arising under Section 139 of the Act by referring its earlier decision in Kumar's case (supra). In those cases the accused has not lead any evidence to rebut the presumption and cross-examination prosecution is not sufficient to rebut the presumption. But here the evidence, both in examination-in-chief and cross examination of complainant coupled with rebuttal evidence adduced by the accused clearly indicates that the presumption of consideration has been rebutted by the respondent- accused even on the basis of the evidence laid by the complainant alone. Apart from it the complainant has not denied defence evidence which is probable defence of accused. The accused has lead legally admissible defence evidence to rebut presumption if any in favour of complainant.
Supreme Court of India Cites 25 - Cited by 2207 - I Banerjee - Full Document

Rohitbhai Jivanlal Patel vs The State Of Gujarat on 18 November, 2020

In other judgment reported as Rohitbhai Jivanlal Patel v. State of Gujarat and Another this Court held as under : (SCC paras, 15, 17 & 22) "15. So far the question of existence of basic ingredients for drawing of presumption under Sections 118 and 139 of the NI Act is concerned, apparent it is that the appellant-accused could not deny his signature on the cheques in question that had been drawn in favour of the complainant on a bank account maintained by the accused for a sum of Rs. 3 lakhs each. The said cheques were presented to the Bank concerned within the period of their validity and were returned unpaid for the reason of either the balance being insufficient or the account being closed. All the basic ingredients of Section 138 as also 18 of Sections 118 and 139 are apparent on the face of the record. The Trial Court had also consciously taken note of these facts and had drawn the requisite presumption. Therefore, it is required to be presumed that the cheques in question were drawn for consideration and the holder of the cheques i.e., the complainant received the same in discharge of an existing debt. The onus, therefore, shifts on the appellant- accused to establish a probable defence so as to rebut such a presumption."
Supreme Court - Daily Orders Cites 0 - Cited by 30 - Full Document
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