A three-judge bench fixed s.138 jurisdiction at the place of dishonour, overruling K. Bhaskaran — only for Parliament to reverse it via the 2015 amendment.
A five-judge Constitution Bench led by CJI S.A. Bobde framed binding directions to streamline cheque-dishonour trials, doubting Meters & Instruments on closure.
A two-judge bench treated cheque dishonour as a compensatory offence and allowed closure on payment — a power the 2021 Constitution Bench later doubted.
A three-judge bench held that each dishonour on re-presentation of a cheque founds a fresh s.138 cause of action, overruling Sadanandan Bhadran's rule.