https://www.livelaw.in/once-liability-and-consideration-proven-by-promissory-note-it-cannot-be-said-that-cheque-was-issued-as-security-offence-us-138-ni-act-proven-sc/
Once liability and consideration proven by Promissory Note, it cannot be said that cheque was issued as ‘Security’; Offence u/s 138 NI Act proven: SC