C.G. Praveen vs Mohd. Tajuddin & Anr

The Supreme Court held that a complaint under Section 138 of the Negotiable Instruments Act, 1881 can be filed by the payee through a power of attorney holder, referencing the precedent set in Shankar Finance and Investments v. State of Andhra Pradesh [(2008) 8 SCC 536]. The Court found that the High Court erred in quashing the prosecution on the grounds that the complaint was not filed by the payee himself. Consequently, the appeal was allowed, the High Court's order was set aside, and the trial court was directed to proceed with the case expeditiously.