Territorial jurisdiction in cheque dishonour cases can lie where any essential statutory act, including notice issuance, occurs.

Territorial jurisdiction for a Section 138 prosecution may rest in any local area where an essential component of the offence occurs, because the offence is completed only through a sequence of statutory acts including drawing and presentation of the cheque, dishonour, notice, and failure to pay within time. Applying Section 178(d) of the Code of Criminal Procedure, a court having jurisdiction over any one such local area may try the case. As the demand notice was issued from Mangalore, that court had jurisdiction, and the challenge to quashing the prosecution failed.

---

---

Issues: Whether the Mangalore Court had territorial jurisdiction to try a prosecution under Section 138 of the Negotiable Instruments Act, 1881, where one of the statutory components of the offence, namely issuance of notice demanding payment, took place within its territorial limits.

Analysis: An offence under Section 138 is completed only when the statutory acts constituting it are fulfilled in sequence, namely drawing of the cheque, presentation, dishonour, issuance of notice, and failure to pay within the stipulated period. These constituent acts may occur in different local areas, and by virtue of Section 178(d) of the Code of Criminal Procedure, 1973, a court having jurisdiction over any one of those local areas may try the offence. Since the notice demanding payment was issued from Mangalore, one of the essential components of the offence occurred there.

Conclusion: The Mangalore Court had jurisdiction to try the complaint, and the challenge to the High Court's refusal to quash the proceedings failed.

Final Conclusion: The appeal did not succeed, and the prosecution was permitted to proceed before the court found to have jurisdiction.

Ratio Decidendi: For an offence under Section 138 of the Negotiable Instruments Act, 1881, jurisdiction may lie in any local area where any essential constituent act of the offence occurs, as such offence is made up of multiple acts capable of being tried under Section 178(d) of the Code of Criminal Procedure, 1973.

---