YOGENDRA PRATAP SINGH vs SAVITRI PANDEY

The Supreme Court held that a complaint under Section 138 of the Negotiable Instruments Act, 1881 cannot be filed before the expiry of the 15-day notice period as mandated by Section 138(c). The Court ruled that the High Court was correct in quashing the Magistrate's order taking cognizance of the complaint filed prematurely. Furthermore, the Court clarified that once the complaint is quashed, the complainant cannot file a new complaint after the one-month period stipulated under Section 142(b) has expired.