Para 1. That the Complainant, Suresh Kumar Sharma, is a law-abiding citizen engaged in Business, residing at the address mentioned hereinabove. The Complainant is the holder of a valid bank account and has been transacting in good faith with the Opposite Party.

Para 2. That the Opposite Party, Vikram Singh Yadav, Proprietor of Yadav Trading Company, is well known to the Complainant and had entered into a financial transaction with the Complainant.

Para 3. On 15.11.2025, the Complainant advanced a loan of ₹5,00,000 (Rupees Five Lakhs Only) to the Opposite Party for business purposes. The Opposite Party issued a cheque bearing No. 001234 drawn on State Bank of India, Aminabad Branch, Lucknow, dated 15.01.2026, for repayment of the said loan amount. When the Complainant presented the said cheque for encashment on 20.01.2026, the same was returned dishonoured by the bank with the endorsement "Funds Insufficient". Despite receiving the statutory demand notice, the Opposite Party has failed and neglected to make payment.

Para 4. That the Opposite Party issued Cheque No. 001234, drawn on State Bank of India, Aminabad Branch, Lucknow, for a sum of ₹5,00,000 (Rupees Five Lakhs Only). The said cheque was presented for encashment by the Complainant, but the same was dishonoured on 20/01/2026 by the bank with the endorsement "Funds Insufficient", thereby committing an offence punishable under Section 138 of the Negotiable Instruments Act, 1881.

Para 5. That the Complainant issued a statutory demand notice to the Opposite Party demanding payment of the dishonoured cheque amount within fifteen (15) days of receipt of the notice. However, the Opposite Party has failed, neglected, and refused to make payment of the said amount despite receipt of the said notice, thereby giving rise to the present cause of action.

Para 6. That the cause of action for filing this complaint arose on 15/11/2025 at Lucknow, Uttar Pradesh and the complaint is within the period of limitation.

Para 7. That this Honourable Court has jurisdiction to entertain and try the present complaint as the Complainant resides within the jurisdiction of this Court and the cause of action partly arose within the territorial jurisdiction of this Honourable Court at Uttar Pradesh.

That the Complainant submits that the act of the Opposite Party is illegal, arbitrary, and contrary to law. The following statutory provisions are attracted to the facts of the present case:

That the Opposite Party is liable to be prosecuted and punished under the above-mentioned provisions of law and is further liable to pay compensation to the Complainant for the losses suffered by the Complainant due to the illegal and wrongful acts of the Opposite Party.

I, Suresh Kumar Sharma, S/o Ramesh Kumar Sharma, aged about 42 years, residing at House No. 47, Sector 12, Indira Nagar, Lucknow, Uttar Pradesh — 226016, do hereby solemnly affirm and verify that the contents of the above complaint from paragraph 1 to the prayer clause are true and correct to the best of my knowledge, information, and belief, and nothing material has been concealed therefrom.

Verified at Lucknow on this 10/06/2026.