Cheque dishonour presumptions prevail unless rebutted by credible evidence that the instrument was only security or unrelated to debt.

Where issuance and dishonour of a cheque are proved, presumptions under the Negotiable Instruments Act operate in favour of the holder, and the accused must rebut them with credible evidence. A bare assertion that the cheque was issued as security or for another transaction is insufficient unless supported by material showing that consideration was improbable, doubtful, or not legally enforceable. On the facts noted, the cheque, signature, bank endorsements, notice, and reply notice supported the complainant's case, and no perversity or legal infirmity was found in the concurrent conviction under Section 138.

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Issues: (i) Whether the concurrent conviction under Section 138 of the Negotiable Instruments Act suffered from an apparent error or perversity warranting revision. (ii) Whether the accused rebutted the statutory presumptions by proving that the cheque was issued only as security or for a different transaction and not towards a legally enforceable debt.

Issue (i): Whether the concurrent conviction under Section 138 of the Negotiable Instruments Act suffered from an apparent error or perversity warranting revision.

Analysis: The cheque, signature, bank endorsements, notice, and reply notice were on record. The complainant proved the foundational facts of issuance, dishonour for insufficiency of funds, and service of notice. The revisional court found no legal infirmity or error apparent on the face of the record in the findings of the courts below.

Conclusion: The conviction and sentence did not suffer from perversity or any error calling for revisional interference.

Issue (ii): Whether the accused rebutted the statutory presumptions by proving that the cheque was issued only as security or for a different transaction and not towards a legally enforceable debt.

Analysis: Once execution of the cheque was admitted, presumptions under Sections 118 and 138 of the Negotiable Instruments Act operated in favour of the holder. The accused did not produce material to show that consideration was improbable, doubtful, or illegal, nor did he establish that the cheque was not issued towards the debt in question. The use of a blank or incomplete cheque did not by itself defeat liability where the instrument was completed and presented in relation to the proved transaction.

Conclusion: The accused failed to rebut the presumptions, and the cheque was treated as having been issued towards a legally enforceable debt.

Final Conclusion: The revisional challenge failed, and the conviction under Section 138 of the Negotiable Instruments Act stood undisturbed.

Ratio Decidendi: Once issuance and dishonour of a cheque are proved, statutory presumptions arise in favour of the holder, and the accused must rebut them by credible evidence; a mere plea that the cheque was given as security or for another transaction is insufficient without proof.

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