A three-judge bench held that a Section 138 complaint lodged before the 15-day statutory notice period has run is premature and discloses no cause of action, so no cognizance can be taken — even if the period has lapsed by the time the magistrate acts. The Court allowed a fresh complaint to be filed within a month of its judgment.
A single judge of the Delhi High Court has declined to decide, and instead referred to a Larger Bench, a foundational sequencing question under the new BNSS: on a private complaint, must the accused be heard under the first proviso to Section 223(1) before or after the Magistrate examines the complainant on oath. A digest of the facts, the interpretive conflict over when 'cognizance' is taken, and the questions sent up for authoritative resolution.