Territorial jurisdiction in cheque dishonour cases follows cheque delivery for collection through the payee's account; revision needs illegality or perversity.

Territorial jurisdiction for a cheque dishonour complaint was upheld where the loan transaction, cheque delivery, presentation, account maintenance, and related correspondence were connected with Bijapur, and the cheque was treated as delivered for collection through the complainant's branch account there. The amended jurisdiction scheme under the Negotiable Instruments Act applied, so the earlier rule in Dashrath Rupsingh Rathod did not assist the accused on these facts. Revisional interference was also refused because such interference lies only for illegality or perversity, and the conviction was supported by documentary evidence while the defence of alteration and blank cheque remained unproved.

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Issues: (i) Whether the complaint under Section 138 of the Negotiable Instruments Act, 1881 was entertainable by the Bijapur Court on the question of territorial jurisdiction. (ii) Whether the conviction and sentence called for interference in revision.

Issue (i): Whether the complaint under Section 138 of the Negotiable Instruments Act, 1881 was entertainable by the Bijapur Court on the question of territorial jurisdiction.

Analysis: The loan transaction, loan application, correspondence, maintenance of the account, delivery of the cheque and presentation of the cheque were found to be connected with Bijapur. The cheque was treated as having been delivered for collection through the complainant's branch account at Bijapur. The amended territorial jurisdiction scheme under Section 142 and Section 142A of the Negotiable Instruments Act, 1881 was applied, and the earlier rule in Dashrath Rupsingh Rathod was held not to assist the petitioner on the facts.

Conclusion: The objection to territorial jurisdiction was rejected and the Bijapur Court was held to have jurisdiction.

Issue (ii): Whether the conviction and sentence called for interference in revision.

Analysis: Revisional interference was found to be limited to cases of illegality or perversity. The cheque dishonour case was supported by documentary evidence, while the defence of alteration and blank cheque was not substantiated by defence evidence. The conviction recorded by the courts below was therefore not shown to suffer from any legal infirmity warranting revisional correction.

Conclusion: No ground was made out for interference with the conviction and sentence.

Final Conclusion: The revision failed in its entirety, and the concurrent findings of conviction and sentence were left undisturbed.

Ratio Decidendi: For offences under Section 138 of the Negotiable Instruments Act, 1881, territorial jurisdiction is governed by the amended Section 142 scheme based on the place where the cheque is delivered for collection through the payee's account, and revisional interference is unwarranted absent illegality, perversity, or failure of rebuttal evidence.

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