SUBODH S. SALASKAR vs JAYPRAKASH M. SHAH

The Supreme Court addressed the retrospective applicability of the proviso to Section 142 of the Negotiable Instruments Act, 1881, as amended by the Negotiable Instruments (Amendment and Miscellaneous Provisions) Act, 2002. The Court held that the amendment does not apply retrospectively, affirming that the complaint under Section 138 was barred by limitation. The Court also ruled that the amendment to include Section 420 IPC was justified, as the complaint disclosed sufficient averments for the offence, thus upholding the High Court's decision.