Under the Negotiable Instruments Act, 1881, in absence of contract to the contrary, the liability of…

Section 134 provides that, in the absence of a contract to the contrary, the liability of the maker or drawer of a foreign instrument is regulated "by the law of the place where he made the instrument". The law of the place where the instrument is made payable governs the acceptor and indorser instead, and neither the place of indorsement nor the court hearing the suit decides the drawer's liability.