This research paper delves into the intricate legal landscape surrounding thedishonor of cheques due to insufficient funds within the Indian legal framework.Prior to the introduction of chapter XVII into NI Act, 1881 through the 1988amendment, no specific criminal offense had been established for this offense.As a result, prosecuting the drawer of a dishonored cheque relied heavily on theinterpretation and application of relevant provisions within The IPC, 1860. Theprimary objective of this paper is to analyze the diverse interpretations put forthby the Indian judiciary concerning the concept of Double Jeopardy within thepurview of Section 138 of the NI Act, 1881. Double Jeopardy refers to the legalprinciple that prohibits subjecting an individual to multiple prosecutions orpunishments for the same offense. By conducting an in-depth examination ofcase law, legal precedents, and scholarly literature, this research aims to providea comprehensive understanding of the complexities associated with prosecutingdishonored cheque cases prior to the specific provisions introduced in 1988. Itexplores the judicial perspectives on the application of Double Jeopardy,examining how different interpretations have shaped the legal landscape. Thefindings of this study contribute to the existing body of knowledge by sheddinglight on the legal challenges encountered in prosecuting dishonored chequecases before the enactment of specific legislation. Ultimately, this research paperseeks to promote a nuanced understanding of the historical development andevolution of legal provisions surrounding dishonored cheques in India,providing a foundation for further discourse and potential reforms in this area oflaw.