Hand written note about dishonour of cheque can be considered a notice under Section 138
A handwritten note purported to be sent as an intimation on dishonour of cheque can be assumed as a valid legal notice as prescribed under Section 138 of the Negotiable Instruments Act, 1881 (‘NI Act’) .
It was held that the hand written note was issued within the mandatory period of thirty days of dishonour of cheques in question. The said note contained all the prerequisites forming the very basis of valid notice as prescribed under clause (b) of proviso to Section 138 of the NI Act and thus was a valid legal notice, more so, when the relevant provision of the NI Act does not prescribed any format of legal notice.
[Pawan Kumar Ralli vs. Maninder Singh Narula]