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Issue notice and mention in the notice about the previous bounce too, that will help you upon filing of complaint.That would be a good evidance to prove him defaulter
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Construct your complaint that the cheque was represented as per request and promise by a drawer that he will make funds available if the cheque is represented.
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Cause of action in a prodeeding under NI 138 arises not when the cheque has bounced, but when the drawer fails to clear the debt evenafter the Notice served consequent to the cheque. As such, the earlier instance(s) are not material, but there is no harm in mentioning them.
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