Section 138 NI Act Complaint Draft

IN THE COURT OF THE LEARNED METROPOLITAN MAGISTRATE (NI ACT COURT) AT [DISTRICT]
COMPLAINT CASE NO. ________ OF 2026

IN THE MATTER OF:
[NAME OF COMPLAINANT] ... COMPLAINANT
VERSUS
[NAME OF ACCUSED] ... ACCUSED

COMPLAINT UNDER SECTION 138 READ WITH SECTION 142 OF THE NEGOTIABLE INSTRUMENTS ACT, 1881 FOR THE OFFENCE OF CHEQUE DISHONOUR

The Complainant respectfully submits:
1. That the Complainant is [BUSINESSMAN / PROFESSIONAL] residing at [ADDRESS].
2. That in discharge of existing legal debt, the Accused issued Cheque bearing No. [NO] dated [DATE] for sum of INR [AMOUNT] drawn on [BANK].
3. That upon presentation, the cheque bounced with memo dated [DATE] endorsed "FUNDS INSUFFICIENT".
4. That Complainant dispatched statutory demand notice dated [DATE] via Speed Post on [DATE], delivered to Accused on [DATE].
5. That despite lapse of 15 days, Accused failed to make payment.
PRAYER: Issue process against Accused, summon and punish under Section 138 NI Act and award compensation under Section 357 CrPC / 143A NI Act.

[ADVOCATE FOR COMPLAINANT]