In December 2024 the Ministry of Law told the Lok Sabha that 43,05,932 cheque bounce matters were pending across Indian courts. That is the size of the universe. The eCourtsIndia full-text index returns 3,581 matters when you search for the colloquial term “cheque bounce”, and 21,972 when you search for “dishonour of cheque”. Both are the visible appellate tip of an iceberg whose body sits in 7,000-plus magistrate courts. This post takes the slice we can see and walks through what it tells us about the country’s most common criminal complaint.
The 43 lakh number, and what hides inside it
Cheque bounce is shorthand for a complaint filed under Section 138 of the Negotiable Instruments Act, 1881. The provision was inserted in 1988 and made the dishonour of a cheque issued for the discharge of a debt or liability a criminal offence punishable with up to two years of imprisonment or a fine of twice the cheque amount, or both. Forty years later, the Hon’ble Supreme Court of India has called the resulting docket the single largest contributor to the criminal-court backlog in the country. The Ministry of Law’s Lok Sabha reply in December 2024 put the pending number at 43,05,932, citing data drawn from the National Judicial Data Grid.
The 43 lakh figure is a magistrate-court number. The cases live before the Chief Judicial Magistrate, the Metropolitan Magistrate, the Judicial Magistrate First Class. Most of those orders never get uploaded with a searchable text body, so a free-text search for “NI Act 138” or “cheque bounce” only catches a fraction of the universe — typically the cases that have travelled up to a Sessions Court revision, a High Court Section 482 petition, or the Supreme Court. The eCourtsIndia full-text index reflects exactly that pattern.
The two numbers we can see, and how they differ
| Search term | Hits | Live verification |
|---|---|---|
| “cheque bounce” | 3,581 | search?q=cheque+bounce |
| “dishonour of cheque” | 21,972 | search?q=dishonour+of+cheque |
| “NI Act 138” | ~21,000 | search?q=NI+Act+138 |
| “Section 138” | ~21,000 | search?q=Section+138 |
Reporters who quote one of these numbers should know the others. The 3,581 figure is the strict free-text match for the colloquial term. The 22,000 cluster is the order-text mention of the statutory provision. The 43 lakh figure is the trial-court universe sitting underneath. None of these is wrong; they are different views of different layers.
Status split at the appellate layer
| Status | Cases | Share |
|---|---|---|
| Disposed | 3,003 | 83.9% |
| Pending | 416 | 11.6% |
| Dismissed | 69 | 1.9% |
| Allowed | 47 | 1.3% |
| Other (admitted, hearing, withdrawn) | 46 | 1.3% |
At the appellate-and-above layer the disposal rate is high because these cases have already passed through the magistrate stage. The pendency burden lives at the trial court. The 416 pending appellate matters are dwarfed by the 43 lakh trial-court universe.
State-wise concentration of the appellate docket
| State | Indexed appellate cases | Share | Live verification |
|---|---|---|---|
| Uttar Pradesh | 1,227 | 34.3% | search?q=cheque+bounce&st=UP |
| Delhi | 550 | 15.4% | &st=DL |
| Maharashtra | 310 | 8.7% | &st=MH |
| Karnataka | 225 | 6.3% | &st=KA |
| Telangana | 218 | 6.1% | &st=TS |
| Tamil Nadu | 113 | 3.2% | &st=TN |
| Gujarat | 102 | 2.8% | &st=GJ |
| Andhra Pradesh | 95 | 2.7% | &st=AP |
| Punjab | 83 | 2.3% | &st=PB |
| Bihar | 81 | 2.3% | &st=BR |
UP alone accounts for one-third of the indexed appellate cheque-bounce universe. The Allahabad HC, the largest High Court in India by case volume, is the single largest forum for cheque-bounce revisions and Section 482 quashing petitions. Delhi’s second-place share reflects the capital’s commercial banking concentration. The Maharashtra-Karnataka-Telangana cluster is the western and southern banking and corporate finance footprint.
Where in the courts these cases sit
| Court | Code | Indexed appellate cases |
|---|---|---|
| Allahabad HC | UPHC01 | 1,214 |
| Delhi HC | DLHC01 | 424 |
| Telangana HC | HBHC01 | 210 |
| Hon’ble Supreme Court of India | SCIN01 | 186 |
| Karnataka HC | KAHC01 | 113 |
| Bombay HC OS | HCBM01 | 87 |
| Madras HC | HCMA01 | 83 |
| Patna HC | BRHC01 | 81 |
| Andhra Pradesh HC | APHC01 | 69 |
| MP HC | MPHC01 | 47 |
The 186 cheque-bounce matters at the Hon’ble Supreme Court of India are largely Special Leave Petitions out of HC orders, plus the suo motu writ petition that produced the September 2025 directions. The Allahabad HC’s share at 1,214 (34 percent of the appellate universe) is itself larger than every other High Court combined.
Filing trend at the appellate layer
| Year | Filings (appellate) |
|---|---|
| 2018 | 650 |
| 2022 | 377 |
| 2023 | 321 |
| 2024 | 214 |
| 2025 | 152 (year still in progress) |
The 2018 spike at the appellate layer reflects the after-shock of Meters and Instruments Pvt Ltd v. Kanchan Mehta (2018) 1 SCC 560, in which the Hon’ble Supreme Court held that Section 138 cases could be compounded even after conviction in appropriate cases, opening a settlement route that produced a wave of revision and quashing petitions. The decline since 2018 reflects the cumulative effect of the 2021 amendments to the NI Act (Section 143A and 148, which empower interim compensation and enforcement), the 2022 Allahabad HC and Bombay HC roll-outs of dedicated NI Act benches, and the 2024 Delhi HC rollout of 34 Digital NI Act Courts.
The Supreme Court’s September 2025 directions
In September 2025 the Hon’ble Supreme Court of India issued comprehensive directions in In re: Expeditious Trial of Cases under Section 138 of the N.I. Act. The directions included that every District and Sessions Judge in Delhi, Mumbai, and Calcutta “maintain a dedicated dashboard reflecting the pendency and progress of cases under Section 138 of the NI Act”. The Court also directed courts to offer payment facilities through secure QR codes or UPI links, and that summons expressly mention the respondent’s option to pay the cheque amount at the initial stage. The directions sit on top of an earlier 2021 Constitution Bench ruling in In re: Expeditious Trial of Cases under Section 138 of N.I. Act 1881 (2021) 16 SCC 116, which laid down a series of trial-court reforms.
Which lender owns the trial-court docket
When you cross-reference the trial-court layer with the litigant search, the picture becomes clearer. HDFC Bank’s Criminal Complaint Case docket on eCourtsIndia alone holds 9,15,958 matters, almost all of them Section 138 complaints. That is roughly 21 percent of the entire 43,05,932 pending universe, by a single lender. State Bank of India’s CC docket at litigant?lit=state+bank+of+india&ct=CC shows 81,544 matters. Tata Motors at litigant?lit=tata+motors&ct=CC holds 31,453 captive-finance matters. Reliance Capital at litigant?lit=reliance+capital&ct=CC holds 19,882 from its pre-IBC lending book. The cheque-bounce universe is in essence a private-sector retail lending universe.
Who is on the other side
The respondent side of a Section 138 matter is, in 70-80 percent of cases by our manual sample, an individual borrower. The remaining 20-30 percent is small-and-medium-enterprise proprietors and partnership firms. The cheque amount in dispute, when readable from order text, ranges from a few thousand rupees (consumer durables EMIs, two-wheeler loans) to a few crore (working-capital MSME loans). The criminal-procedure form of the action is, in commercial substance, a debt-recovery action.
A representative case verified for this post
CNR DLHC010095422019 at the Hon’ble Delhi HC, filed by Reena Gambhir against the State, is a Criminal Miscellaneous Application that consolidated multiple Section 138 cases arising out of the same transaction. The Hon’ble Delhi HC held that consolidation was permissible where the cheques formed part of a single underlying liability. This is one of many appellate-layer matters that show the procedural innovation that has emerged around the bare provisions of Section 138.
The Digital NI Act court rollout
The Hon’ble Delhi HC rolled out 34 dedicated Digital NI Act Courts in the 2024 to 2025 cycle. Other High Courts have followed, with the Bombay HC, Madras HC, and Karnataka HC all running pilots in 2025 to 2026. The architecture is paperless: digital summons, digital evidence, digital recording, digital disposal. As the rollout completes over the next three years, the share of Section 138 litigation that lives inside these courts will grow, and the eCourtsIndia data feed will continue to capture them automatically.
What this means for lenders, regulators, and litigants
For a lender, the Hon’ble Supreme Court’s 2025 dashboard direction is now an operational requirement. The Court ordered the courts to publish dashboards. A lender that cannot reconcile its own portfolio against the court’s dashboard is operating without a feedback loop. The eCourtsIndia API is one path to that reconciliation, as we covered in the Section 138 dashboard architecture post.
For a regulator, the case-volume distribution is a portfolio risk indicator. A lending product with disproportionate concentration in any one state or one magistrate court is, on its face, a portfolio that has lost its geographic and underwriting discipline. The RBI’s Department of Supervision can read the eCourtsIndia data the same way the lenders can.
For a defaulting borrower, the 2025 directions make the early-payment route real. Paying the cheque amount before the first hearing closes the matter without conviction. The QR-code summons that the Hon’ble Supreme Court mandated puts that option in the borrower’s hand from day one.
Replication and methodology
Every total in this post comes from one of these calls. The headline figure is search_cases(query="cheque bounce", pageSize=1). The state-wise breakdown comes from the stateCode facet in the same response. The court-wise breakdown comes from the courtCode facet. The filing-year trend comes from the filingYear facet. The litigant-by-litigant figures (HDFC Bank, SBI, Tata Motors, Reliance Capital) come from search_cases(litigants="<name>", caseTypes="CC", pageSize=1).
The Ministry of Law’s 43,05,932 figure is from the written reply by the Hon’ble Minister of Law to a Lok Sabha question on 6 December 2024 (Unstarred Question No. 1144), citing data drawn from the National Judicial Data Grid. The Hon’ble Supreme Court’s September 2025 directions are reported as In re: Expeditious Trial of Cases under Section 138 of the N.I. Act.
Verification links for every claim in this post
- “cheque bounce” full-text search: https://ecourtsindia.com/search?q=cheque+bounce
- “dishonour of cheque” full-text search: https://ecourtsindia.com/search?q=dishonour+of+cheque
- “NI Act 138”: https://ecourtsindia.com/search?q=NI+Act+138
- “Section 138”: https://ecourtsindia.com/search?q=Section+138
- HDFC Bank CC docket: https://ecourtsindia.com/litigant?lit=hdfc+bank&ct=CC
- SBI CC docket: https://ecourtsindia.com/litigant?lit=state+bank+of+india&ct=CC
- Tata Motors CC docket: https://ecourtsindia.com/litigant?lit=tata+motors&ct=CC
- Reliance Capital CC docket: https://ecourtsindia.com/litigant?lit=reliance+capital&ct=CC
- Allahabad HC cheque-bounce docket: https://ecourtsindia.com/search?q=cheque+bounce&cc=UPHC01
- Delhi HC cheque-bounce docket: https://ecourtsindia.com/search?q=cheque+bounce&cc=DLHC01
- Supreme Court cheque-bounce docket: https://ecourtsindia.com/search?q=cheque+bounce&cc=SCIN01
43 lakh pending Section 138 matters is not a backlog. It is a product feature of the way India lends to retail. The Hon’ble Supreme Court has now ordered the courts to keep score. The lenders should keep their own.
Further reading: Cheque Bounce at Scale: Tracking 43 Lakh Section 138 NI Act Cases With the eCourtsIndia API, The Bank Litigation Index, The Conglomerate Litigation Map, Litigation Portfolio Monitoring for General Counsel.