Relevance of precedent on timely complaints

The judgment discussed Dashrath Rupsingh Rathod v. State of Maharashtra. That decision addressed the restriction on cognisance under Section 142. Cognisance requires a written complaint by the payee or holder in due course. The complaint must meet the time limit linked to Section 138. The cause of action arises under clause (c) of the Section 138 proviso. Section 142’s proviso allows delayed cognisance only for sufficient cause. The Court applied the statutory text as amended. Limitation had to be resolved before cognisance of the delayed complaint. (S. Nagesh v. Shobha S. Aradhya | 2026 INSC 27)