Under the Negotiable Instruments Act, 1881, the liability of the indorser of a foreign instrument is…

Section 134 regulates the respective liabilities of the acceptor and the indorser "by the law of the place where the instrument is made payable". The place where the indorsement was made is a tempting choice, but it does not govern; the law of the place of making governs only the maker or drawer. This statutory default applies absent a contract to the contrary.