Second or successive statutory notice can also form basis of proceedings under S138 Supreme Court overturns Sadanandan Bhadran

On September 26, 2012 a Bench of Justices RM Lodha, TS Thakur and Anil Dave pronounced its judgment in MSR Leathers v S. Palaniappan & Anr, marking a crucial change in the jurisprudence of proceedings under Section 138 of the Negotiable Instruments Act, 1881 (the Act). The judgment also overturns the Court’s earlier decision in Sadanandan Bhadran v. Madhavan Sunil Kumara [(1998) 6 SCC 514].

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