The significant effect of Section 25(3) of the Indian Contract Act on the defence of time-barred debt in NI Case can not be ignored. We will analyze a recent Hon’ble High Court Judgment that explains the importance of Section 25(3) of the Indian Contract in a NI Act case. The key question answered is regarding the validity of a cheque for a time-barred debt. The Hon’ble Court clarified how such a cheque constitutes a ‘fresh promise’ under Section 25(3) of the Contract Act, thereby reviving the debt and making it legally enforceable. Understanding the effect of Section 25(3) of the Indian Contract Act on the defence of time-barred debt is crucial for both complainants and accused.
STAY UPDATED: We are constantly tracking the latest legal developments on this topic. This article will be updated with recent Judgments from the Hon’ble Supreme Court and High Courts to provide the most current understanding of the effect of Section 25(3) of the Indian Contract Act on the defence of time-barred debt and the validity of a cheque for a time-barred debt.
Delhi High Court Judgment SHARDHA NAND BANSAL VERSUS ASHOK KUMAR BHALLA CRL.REV.P.(NI) 44/2025
YOUTUBE VIDEO: To understand the complex interaction between the NI Act and the Contract Act, watch our detailed video. We visually explain the effect of Section 25(3) of the Indian Contract Act on the defence of time-barred debt and how a ‘fresh promise’ under Section 25(3) of the Contract Act can secure a conviction. Click the link to learn about the importance of Section 25(3) of the Indian Contract in a NI Act case.
The concepts surrounding a ‘fresh promise’ under Section 25(3) of the Contract Act and its impact on what constitutes a legally enforceable debt can be complex. Whether you are assessing the validity of a cheque for a time-barred debt as a complainant or facing a defence of a time-barred debt as an accused, navigating this legal landscape requires precise understanding.
If you need clarity on your specific situation or want to understand how the effect of Section 25(3) of the Indian Contract Act on the defence of time-barred debt applies to your case, you can book a consultation to discuss your matter in detail. Schedule an Appointment.
To help you navigate this important Judgment, here is a detailed table of contents. We will explore the case facts, the arguments from both sides, and the Hon’ble High Court’s definitive findings on the effect of Section 25(3) of the Indian Contract Act on the defence of time-barred debt.
Table of Contents
- Case Details: Effect of Section 25(3) of Indian Contract on defence of Time-Barred Debt
- Factual Background: How a Loan Case Raised the Effect of Section 25(3) of Indian Contract on defence of Time-Barred Debt
- Journey Through the Lower Courts: Initial Rulings Leading to the High Court’s Analysis of the Effect of Section 25(3) of Indian Contract on defence of Time-Barred Debt
- Core Legal Question at the Hon’ble High Court: Is Time-Barred Debt a Legally Enforceable Debt?
- Petitioner’s (Accused) Challenge: Why the Debt Was Not Legally Enforceable
- Respondent’s (Complainant’s) Rebuttal: A Valid and Enforceable Liability
- Hon’ble High Court’s Verdict: The Importance of Section 25(3) of Indian Contract in a NI Act Case
- Analysis 1: Was the Debt Time-Barred?
- Analysis 2: The Legal Effect of Section 25(3) of Indian Contract on defence of Time-Barred Debt
- What is a ‘Fresh Promise’ Under Section 25(3) of the Contract Act?
- Precedents Cited: Hon’ble Court on the Validity of a Cheque for a Time-Barred Debt
- Analysis 3: Debunking the “Security Cheque” Defence
- Analysis 4: Why the Repayment Defence (Ex. DW1/1) Failed
- Final Judgment: Conviction Upheld, Confirming the Effect of Section 25(3) of Indian Contract on defence of Time-Barred Debt
- Frequently Asked Questions (FAQ)
1. Case Details: Effect of Section 25(3) of Indian Contract on defence of Time-Barred Debt
This article analyzes a significant Judgment from the Hon’ble High Court of Delhi that directly addresses a critical issue in cheque bounce litigation: the effect of Section 25(3) of the Indian Contract Act on the defence of time-barred debt . The Hon’ble Court examined whether a cheque issued for a loan that was, on its face, barred by limitation, could still be considered a “legally enforceable debt” . This decision clarifies the importance of Section 25(3) of the Indian Contract in a NI Act case, particularly how it creates a ‘fresh promise’ under Section 25(3) of the Contract Act.
- Title of the Judgement: SHARDHA NAND BANSAL versus ASHOK KUMAR BHALLA
- Name of the Judge: Hon’ble Ms. Justice Neena Bansal Krishna
- Citation Number of the Judgement: CRL.REV.P.(NI) 44/2025
- Date of the Judgment: Pronounced on 25th September, 2025
2. Factual Background: How a Loan Case Raised the Effect of Section 25(3) of Indian Contract on defence of Time-Barred Debt
The case began with a financial transaction between two parties that eventually led to a cheque dishonour complaint. The accused, however, raised a fundamental defence that the debt itself was too old to be enforced, bringing the effect of Section 25(3) of the Indian Contract Act on the defence of time-barred debt into sharp focus .
2.1. Complainant’s Case: A Friendly Loan and Dishonoured Cheques
The Respondent/Complainant, Ashok Kumar Bhalla, filed a complaint under Section 138 of the NI Act. His case was:
- He advanced a friendly loan of Rs. 25,00,000 to the Petitioner/Accused, Shardha Nand Bansal, for his construction business.
- The loan was secured by a Mortgage Deed dated 25.07.2013.
- In discharge of this liability, the accused issued two cheques in 2018:
- One cheque for Rs. 25,00,000 (principal) dated 24.08.2018 .
- Another cheque for Rs. 14,00,000 (interest) dated 16.08.2018.
- Both cheques were returned unpaid for “Funds Insufficient” on 28.08.2018.
- Despite a statutory Legal Notice dated 17.09.2018, the accused failed to pay, leading to the criminal complaint filed on 18.10.2018.
2.2. Accused’s Defence: Allegations of Security Cheques and Loan Repayment
When the accused was notified of the charges by the Learned Trial Court, he pleaded not guilty . His primary defence was twofold:
- The cheques in question were given as “security” for the loan.
- The entire loan amount had already been repaid, and the complainant had misused the security cheques.
2.3. Case Timeline: From Loan in 2013 to Conviction Challenge in 2025
- 25.07.2013: Friendly loan of Rs. 25,00,000 advanced; First Mortgage Deed executed.
- 23.07.2014: Original repayment date stipulated in the first Mortgage Deed.
- 22.07.2014: A Second Mortgage Deed was executed, extending the repayment date.
- 08.08.2015: The repayment date mentioned in the Second Mortgage Deed.
- 10.06.2015: Complainant sends a Demand Letter (Ex. CW-1/A3) referencing the 08.08.2015 due date .
- March 2018: Complainant testifies that the two post-dated cheques were given to him by the accused.
- 16.08.2018 & 24.08.2018: Dates of the two dishonoured cheques .
- 28.08.2018: Both cheques returned for “Funds Insufficient”.
- 17.09.2018: Statutory Legal Notice sent by the Complainant.
- 18.10.2018: Criminal Complaint under S.138 NI Act filed.
- 18.11.2023: Learned MM passes the Judgment of conviction.
- 22.11.2023: Learned MM passes the Order on Sentence.
- 23.01.2025: Learned ASJ dismisses the appeal, upholding the conviction.
- 25.09.2025: Hon’ble High Court of Delhi pronounces its Judgment on the Revision Petition.
3. Journey Through the Lower Courts: Initial Rulings Leading to the High Court’s Analysis of the Effect of Section 25(3) of Indian Contract on defence of Time-Barred Debt
The accused’s challenge was not successful in the lower judiciary. Both the Learned Trial Court and the Learned First Appellate Court convicted the accused, leading to the Revision Petition before the Hon’ble High Court where the effect of Section 25(3) of the Indian Contract Act on the defence of time-barred debt was conclusively decided.
3.1. Learned Metropolitan Magistrate (MM): Conviction and Sentence
After the trial, the Learned Metropolitan Magistrate (MM) found the accused’s defence to be unsubstantiated.
- Judgment of Conviction (18.11.2023): The petitioner was convicted for the offence under Section 138 of the NI Act.
- Order on Sentence (22.11.2023): The petitioner was sentenced to imprisonment Till the Rising of the Court and ordered to pay compensation of Rs. 75,00,000 .
3.2. Learned Additional Sessions Judge (ASJ): Appeal Dismissed, Conviction Upheld
Aggrieved by the conviction, the petitioner filed an appeal before the Learned Additional Sessions Judge (ASJ). The Learned ASJ re-appreciated the evidence and arguments but concurred with the findings of the Learned MM. The appeal was dismissed in a detailed Judgment dated 23.01.2025. It was only at this appeal stage that the accused raised the specific issue of the debt being time-barred. The Learned ASJ rejected this ground, noting that subsequent documents, like the 2015 demand letter, showed the repayment was “kept open”.
4. Core Legal Question at the Hon’ble High Court: Is Time-Barred Debt a Legally Enforceable Debt?
Aggrieved by the concurrent convictions, the petitioner filed the present Revision Petition before the Hon’ble High Court of Delhi.
The central issue for the Hon’ble Court’s consideration was whether the conviction could be sustained, particularly concerning the petitioner’s primary defence: that the cheques were issued for a debt that was barred by limitation and therefore was not a “legally enforceable debt”.
The Explanation to Section 138 of the NI Act clarifies that the “debt or other liability” must be a “legally enforceable debt or other liability”. The petitioner’s entire case rested on the argument that the original loan from 2013, repayable by 2014, had its three-year limitation period expire in 2017 . Therefore, in 2018, no “legally enforceable debt” existed, making the S.138 complaint invalid. This set the stage for the Hon’ble Court to analyze the validity of a cheque for a time-barred debt.
5. Petitioner’s (Accused) Challenge: Why the Debt Was Not Legally Enforceable
Before the Hon’ble High Court, the Petitioner (accused) raised several grounds to challenge his conviction, all aimed at proving that no “legally enforceable debt” existed when the cheques were presented .
5.1. Main Contention: The Defence of a Time-Barred Debt
The petitioner’s primary argument was that the debt was hopelessly time-barred.
- He argued that the loan was advanced under a Mortgage Deed dated 25.07.2013.
- This deed stipulated that the amount was to be repaid on or before 23.07.2014.
- Therefore, the three-year limitation period to enforce this debt expired on 22.07.2017.
- Since the cheques were presented in August 2018, he claimed they were not for a “legally enforceable debt”.
5.2. Contention 2: Cheques Were Given as Security
The petitioner further contended that the cheques were handed over as “Security” back in 2013 when the loan was first given. He alleged that the respondent (complainant) had subsequently misused these security cheques in 2018.
5.3. Contention 3: Alleged Full and Final Repayment
The petitioner also claimed that the trial courts ignored crucial evidence of repayment. He relied on:
- A payment Receipt dated 01.11.2018 (Ex. DW1/1), which was supposedly proven by a defence witness (DW1), indicating a full and final settlement .
- He also claimed the Trial Court wrongly closed his opportunity to summon a bank witness to prove other payments made to the respondent.
6. Respondent’s (Complainant’s) Rebuttal: A Valid and Enforceable Liability
The Respondent (complainant) strongly opposed the petitioner’s arguments, asserting that the conviction was sound and based on a valid, legally enforceable debt.
6.1. Cheques Issued for a Legally Enforceable Debt
The complainant argued that the cheques were issued against a legally enforceable debt and were well within the limitation period. The dishonour for “insufficient funds” was proven, and all procedural requirements of Section 138 were met.
6.2. Rebutting the ‘Security Cheque’ Argument
The respondent argued that the defence of “security cheques” is contrary to settled law. It was submitted that a cheque issued as security still creates a liability if the underlying debt remains outstanding on the date of its presentation. Once the petitioner admitted his signatures, the statutory presumption under Section 139 NI Act was raised, which the petitioner failed to rebut .
6.3. Repayment Defence Discredited as an “Afterthought”
The complainant argued that the petitioner’s claim of full repayment, built around the Receipt dated 01.11.2018, was a “bald assertion”. This defence was rightly disbelieved by the courts because the receipt was dated after the criminal complaint was filed on 18.10.2018, making it a clear “afterthought”.
7. Hon’ble High Court’s Verdict: The Importance of Section 25(3) of Indian Contract in a NI Act Case
The Hon’ble High Court, after perusing the record and hearing submissions, conducted a detailed analysis of the petitioner’s “time-barred debt” defence and delivered a conclusive finding on the importance of Section 25(3) of the Indian Contract in a NI Act case.
7.1. Analysis 1: Was the Debt Time-Barred?
The Hon’ble Court first examined the timeline. While the first Mortgage Deed set a 2014 repayment date, the Court noted the execution of a Second Mortgage Deed dated 22.07.2014, which extended the repayment date to 08.08.2015 . This was further supported by a Demand Letter dated 10.06.2015 (Ex.CW1/A3) sent by the complainant.
The complainant’s testimony was that the two post-dated cheques were given to him in March 2018. The Hon’ble Court found that the petitioner’s act of handing over these cheques in March 2018 amounted to an acknowledgment of the existing debt.
7.2. Analysis 2: The Legal Effect of Section 25(3) of Indian Contract on defence of Time-Barred Debt
This was the central legal finding. The Hon’ble Court held that even if the debt was time-barred, the petitioner’s defence would still fail due to Section 25(3) of the Indian Contract Act, 1872 .
The Hon’ble Court explained that Section 25(3) provides that a promise made in writing and signed by the person, to pay a debt which the creditor might have enforced but for the law of limitation, is a valid and enforceable contract.
7.3. What is a ‘Fresh Promise’ Under Section 25(3) of the Contract Act?
The Hon’ble Court clarified that a cheque is, by its very nature, a promise to pay. The Judgment states:
“The drawer of a cheque promises to the person in whose name the cheque is drawn… that the cheque on its presentation would yield the amount specified therein. Hence, it will have to be held that a cheque is a promise within the meaning of Sub-section (3) of Section 25 of the Contract Act.”
Therefore, when the petitioner issued the cheques in 2018, he made a ‘fresh promise’ under Section 25(3) of the Contract Act.
This fresh promise created a new, valid, and legally enforceable liability, even if the original debt had become time-barred. The validity of a cheque for a time-barred debt was thus affirmed.
7.4. Precedents Cited: Hon’ble Court on the Validity of a Cheque for a Time-Barred Debt
The Hon’ble Court relied on established legal precedent to support its finding:
- A.V. Murthy VS. B.S. Nagabasavanna (2002): The Hon’ble Apex Court held that a promise to pay a time-barred debt becomes a valid contract under Section 25(3) of the Indian Contract Act . The Hon’ble Supreme Court also noted that showing the amount in a balance sheet could amount to an acknowledgment, giving the creditor a fresh period of limitation .
- Dinesh B. Chokshi vs Rahul Vasudeo Bhatt (2012): The Hon’ble Bombay High Court observed that a cheque drawn to pay a time-barred debt is a promise governed by Section 25(3) and is, therefore, valid and enforceable .
- Rajeev Kumar vs The State NCT Of Delhi & Anr. (2024): A coordinate Bench of the Hon’ble Delhi High Court held that furnishing a cheque for a time-barred debt “effectively resurrects the debt itself” and triggers the provisions of Section 138 of the NI Act .
7.5. Analysis 3: Debunking the “Security Cheque” Defence
The Hon’ble High Court completely dismantled the petitioner’s “security cheque” defence, noting several critical failures:
- The petitioner failed to step into the witness box himself to prove this defence.
- He gave no suggestion to the complainant during cross-examination that the cheques were given as security.
- He failed to state when these alleged security cheques were handed over.
- Crucially, there was “not a whisper” of any undated security cheques being issued in either of the two detailed Mortgage Deeds (dated 2013 and 2014). The Hon’ble Court found it “highly improbable” that such a crucial element would not be mentioned.
7.6. Analysis 4: Why the Repayment Defence (Ex. DW1/1) Failed
The petitioner’s final defence of repayment was also found to be non-credible:
- Contradictory Evidence: The petitioner claimed in his statement (u/s 313 Cr.P.C) that he paid Rs. 14 lakhs in cash himself. However, his witness (DW1) claimed he paid the Rs. 14 lakhs on the petitioner’s behalf. The Receipt (Ex.DW1/1) itself stated the money was given by the petitioner, not DW1 . The Hon’ble Court noted this “serious discrepancy”.
- Timing: The alleged full and final settlement Receipt (01.11.2018) was dated after the criminal complaint was filed (18.10.2018).
- Absence from Witness Box: The petitioner himself did not enter the witness box to prove this repayment receipt. The Hon’ble Court concluded this defence was “an afterthought and devoid of credibility”.
8. Final Judgment: Conviction Upheld, Confirming the Effect of Section 25(3) of Indian Contract on defence of Time-Barred Debt
The Hon’ble High Court concluded that the petitioner had “miserably failed” to rebut the statutory presumption under Section 139 of the NI Act. A mere assertion of repayment or misuse of security cheques, without corroborative evidence, is insufficient to dislodge this presumption.
The Hon’ble Court found “no perversity, jurisdictional error, or manifest illegality” in the concurrent findings of the Learned MM and the Learned ASJ.
Accordingly, the Criminal Revision Petition was dismissed, and the judgment of conviction dated 18.11.2023 and order on sentence dated 22.11.2023 were affirmed and upheld .
8.1. Key Takeaways for Complainants and Accused
This Judgment provides critical clarity on the question: Is time barred debt not a Legally Enforceable Debt?
- For Complainants: This Judgment is a powerful tool. If an accused issues a fresh cheque, even for a very old or time-barred debt, that cheque can be considered a ‘fresh promise’ under Section 25(3) of the Contract Act. This act “resurrects” the debt, making it legally enforceable under Section 138.
- For Accused: This Judgment serves as a stark warning. The defence that a debt is “time-barred” is completely neutralized if a fresh cheque is issued. The act of signing and issuing that cheque creates a new and enforceable contract . Furthermore, inconsistent or “afterthought” defences, such as repayment receipts created after the complaint is filed, will be viewed with high suspicion and are unlikely to succeed.
The concepts surrounding a ‘fresh promise’ under Section 25(3) of the Contract Act and its impact on what constitutes a legally enforceable debt can be complex. Whether you are assessing the validity of a cheque for a time-barred debt as a complainant or facing a defence of a time-barred debt as an accused, navigating this legal landscape requires precise understanding.
If you need clarity on your specific situation or want to understand how the effect of Section 25(3) of the Indian Contract Act on the defence of time-barred debt applies to your case, you can book a consultation to discuss your matter in detail. Schedule an Appointment.
9. Frequently Asked Questions (FAQ)
Q1. What is a “time-barred debt” in a cheque bounce case?
A time-barred debt is a loan or debt that can no longer be legally recovered through a civil lawsuit because the time limit (usually three years) for filing the suit has passed. In a cheque bounce case, an accused might argue that since the original debt is time-barred, it is not a “legally enforceable debt,” and therefore, a cheque issued for it is not valid under Section 138 of the NI Act .
Q2. What was the main legal question in the SHARDHA NAND BANSAL versus ASHOK KUMAR BHALLA case?
The main legal question was whether a cheque issued in 2018 for a loan taken in 2013 (which was repayable by 2014) was for a “legally enforceable debt.” The accused’s defence was that the debt had become time-barred and was unenforceable, so the cheque bounce complaint was not maintainable .
Q3. Is a cheque for a time-barred debt valid and enforceable?
Yes. This Judgment affirms that a cheque issued for a time-barred debt is valid and enforceable. The Hon’ble Court held that the cheque itself constitutes a “fresh promise” in writing under Section 25(3) of the Indian Contract Act, 1872 . This “resurrects” the debt, making it a new, valid, and legally enforceable contract .
Q4. Is a time-barred debt a “legally enforceable debt” under Section 138 of the NI Act?
Ordinarily, a debt that is time-barred is not legally enforceable. However, this Judgment clarifies that when a person issues a cheque for that time-barred debt, the cheque itself acts as a new promise under Section 25(3) of the Contract Act. This new promise creates a fresh, legally enforceable liability, bringing it back within the scope of Section 138 of the NI Act .
Q5. What is the effect of Section 25(3) of the Indian Contract Act on the defence of a time-barred debt?
The effect is that it completely neutralizes the “time-barred debt” defence. Section 25(3) states that a written promise to pay a debt, which is barred by limitation, is a valid contract. The Hon’ble Court held that a cheque is a written promise. Therefore, issuing a cheque for a time-barred debt creates a new, enforceable contract, and the “time-barred” defence fails .
Q6. What is a ‘fresh promise’ under Section 25(3) of the Contract Act?
As explained by the Hon’ble Court, a ‘fresh promise’ is a promise made in writing and signed by a person, to pay a debt that the creditor could no longer enforce due to the law of limitation. The Judgment confirms that a cheque itself is a “promise… within the meaning of Sub-section (3) of Section 25 of the Contract Act” .
Q7. What is the importance of Section 25(3) of the Indian Contract Act in an NI Act case?
Its importance is crucial for complainants. It allows them to prosecute a cheque bounce case even if the underlying loan or debt was very old. The act of issuing the cheque “resurrects” the debt, making it legally enforceable and allowing the complainant to invoke the penal provisions of Section 138 of the NI Act .
Q8. What happens if I issue a new cheque for an old, time-barred loan?
If you issue a new cheque for a time-barred loan, you are creating a new, written promise to pay that debt. The Hon’ble Court held this act creates a fresh, enforceable liability under Section 25(3) of the Contract Act. You can be prosecuted under Section 138 of the NI Act if that new cheque is dishonoured .
Q9. Can I be convicted under Section 138 for a security cheque?
Yes. The law (and the complainant’s argument in this case) holds that a cheque issued as security still creates a liability if the underlying debt remains outstanding on the date the cheque is presented . In this case, the Hon’ble Court also found the accused’s “security cheque” defence was not credible because he failed to prove it and it was never mentioned in the original loan (Mortgage) deeds .
Q10. How to enforce a cheque given for a very old loan?
This Judgment shows that the cheque itself is the key. You can argue that the cheque, even if given for an old or time-barred loan, acts as a ‘fresh promise’ under Section 25(3) of the Indian Contract Act. This new promise “resurrects” the debt, making it a legally enforceable liability under Section 138 of the NI Act.
Q11. How to counter the ‘security cheque’ defense in a 138 case?
The complainant in this case successfully countered this defence by arguing that a security cheque is still valid if the debt is outstanding when it’s presented . The Hon’ble Court also noted the defence was weak because the accused failed to prove it, and more importantly, the detailed loan agreements (Mortgage Deeds) made “not a whisper” of any security cheques, which was “highly improbable” .
Q12. Why did the Hon’ble Court reject the accused’s defence that he had already repaid the loan?
The Hon’ble Court rejected it for several reasons:
- Contradictions: The accused claimed he paid Rs. 14 lakhs in cash, but his witness (DW1) claimed he paid it on the accused’s behalf. The receipt itself contradicted the witness .
- Timing: The alleged “full and final” payment receipt was dated 01.11.2018, which was after the criminal complaint had already been filed on 18.10.2018 .
- Lack of Proof: The accused never stepped into the witness box himself to prove the payment or the receipt.
Q13. How to prove I repaid a loan in cash in a cheque bounce case?
The article highlights how the accused in this case failed to prove his cash repayment. His defence was weak because his witness’s testimony contradicted his own statement , he did not step into the witness box to prove the payment receipt, and the source of the large cash amount was not explained. This implies that to succeed, you need consistent evidence, credible testimony (including your own), and clear proof of the source of funds.
Q14. What if the accused creates a fake repayment receipt after the complaint is filed?
The Hon’ble High Court, agreeing with the lower courts, found such a receipt to be non-credible. A receipt dated 01.11.2018, which was created after the complaint was filed on 18.10.2018, was seen as a self-serving document and an “afterthought” that was “devoid of credibility” .
Q15. What is the defense if a complaint is filed before I made the payment?
This is not a valid defence. In the case analyzed, the accused tried to rely on a payment receipt dated after the criminal complaint was already filed. The Hon’ble Court dismissed this defence as an “afterthought and devoid of credibility” .
Q16. What happens if an accused’s testimony contradicts their own witness’s testimony?
It severely damages the credibility of the defence. In this case, the Hon’ble Court noted a “serious discrepancy” because the accused said he paid the cash, but his witness said he paid the cash. This inconsistency led the Hon’ble Court to find the testimony of the witness to be of “no credence” .
Q17. What key legal precedents did the Hon’ble Delhi High Court rely on?
The Hon’ble Court relied on several key precedents to establish that a cheque for a time-barred debt is valid:
- A.V. Murthy VS. B.S. Nagabasavanna (2002): A Hon’ble Supreme Court case which held that a promise to pay a time-barred debt becomes a valid contract under Section 25(3) .
- Dinesh B. Chokshi vs Rahul Vasudeo Bhatt (2012): A Hon’ble Bombay High Court case which observed that a cheque for a time-barred debt is a valid and enforceable promise .
- Rajeev Kumar vs The State NCT Of Delhi & Anr. (2024): A case from the Hon’ble Delhi High Court which held that a cheque “effectively resurrects the debt itself” .
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