Territorial jurisdiction for cheque dishonour complaints lies where the payee's account is maintained under the amended law.

Under the amended jurisdictional scheme in Section 142(2) of the Negotiable Instruments Act, territorial jurisdiction for a Section 138 complaint depends on where the cheque is delivered for collection through an account. Cheques routed through a collection arrangement and credited to the complainant's account at Bank of Baroda, Vadodara, were treated as presented through that account even though physically deposited at Corporation Bank, New Delhi. The explanation to Section 142(2) deemed delivery at any branch of the payee's bank to be delivery at the branch where the account is maintained. Section 201 CrPC was held inapplicable after cognizance and issuance of process.

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Issues: Whether the Court at Vadodara had territorial jurisdiction to try complaints under Section 138 of the Negotiable Instruments Act, 1881 when the cheques were deposited through the complainant's collection arrangement with Corporation Bank and credited to the complainant's account at Bank of Baroda, Vadodara.

Analysis: The amended jurisdictional scheme under Section 142(2) of the Negotiable Instruments Act, 1881 makes the place where a cheque is delivered for collection through an account the determinative factor for jurisdiction. The complaint materials and the bank certificate showed that the cheques, though physically deposited at Corporation Bank, New Delhi, were part of the complainant's Fast Collection Service arrangement and were credited to the complainant's account maintained at Bank of Baroda, Vadodara. The cheques were account payee cheques and could not realistically be treated as presented otherwise than through an account. The explanation to Section 142(2) reinforced that delivery at any branch of the payee's bank is deemed delivery to the branch where the account is maintained. Section 201 of the Code of Criminal Procedure, 1973 had no application after cognizance and issuance of process.

Conclusion: The Court at Vadodara had territorial jurisdiction, and the quashing applications were rejected.

Ratio Decidendi: For an account payee cheque routed through a bank collection facility and ultimately credited to the payee's account, jurisdiction under Section 142(2)(a) of the Negotiable Instruments Act, 1881 lies with the court where the payee's account is maintained, and the existence of a collection intermediary does not shift jurisdiction to the place of physical deposit.

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