As per case facts, applicants issued cheques on State Bank of Patiala for loan repayment, which were returned for 'Insufficient Funds'. Despite bank merger making the original cheques invalid after ... a certain period, they were presented later. After process issuance by the Magistrate and dismissal of revision applications by the Sessions Judge, applicants approached the High Court arguing cheques were invalid due to bank merger, thus Section 138 N.I. Act shouldn't apply. The question arose whether a cheque returned for 'Insufficient Funds' after a bank merger, leading to its alleged invalidity, precludes liability under Section 138. Finally, the High Court held that when cheques are returned for 'Insufficient Funds', the validity issue due to bank merger is a factual matter for trial, activating statutory presumptions. Dismissing the applications, the Court stated no straight-jacket formula exists for quashing based on alleged invalidity when the return memo cites insufficient funds.