Negotiable Instruments Act Section 134 — Law governing liability of maker, acceptor or indorser of foreign instrument

CHAPTER XVI O F I N T E R N A T I O N A L LA W

General

Summary

Unless the parties have agreed otherwise, the person who makes or draws a foreign promissory note, bill of exchange, or cheque is held responsible according to the law of the place where they created the instrument. The acceptor and the indorser, however, are held responsible according to the law of the place where the instrument is supposed to be paid. This means the location of making and the location of payment can determine which country's legal rules apply to each person's obligations.

Official Text

In the absence of a contract to the contrary, the liability of the maker or drawer of a foreign promissory note, bill of exchange or cheque is regulated in all essential matters by the law of the place where he made the instrument, and the respective liabilities of the acceptor and indorser by the law of the place where the instrument is made payable.