This case arises from a reference made by a two-judge bench of the Supreme Court regarding the liability of company officers under Sections 138 and 141 of the Negotiable Instruments ... Act, 1881. The appellant, S.M.S. Pharmaceuticals Ltd., challenged the prosecution of its officers for dishonor of a cheque issued by the company. The central questions revolved around whether a complaint must specifically aver that a person accused under Section 141 was in charge of and responsible for the conduct of the company’s business and whether directors or signatories of the cheque are automatically liable.