In Sampelly Satyanarayana Rao vs. Indian Renewable Energy Development Agency Limited, 2016, the reimbursed cheques were issued to meet obligations to pay future instalments of the repayable amount in accordance with the agreement between the parties. – The judgment also stated that it could not be ignored an essential fact that article 139 of the Negotiable Instruments Act obliges the Court of Justice to consider that the holder of the cheque received it for deleveraging or liability and that the burden lay with the accused to rebut the presumption. one. The holder of a disgraced cheque may lodge the following appeal: The decision of the Delhi Supreme Court has been challenged before the Supreme Court. .