It is the custom of banks when issuing bank cheques to have them made over to the name of the payee or bearer crossed and marked ’not negotiable’. The practice of banks in England is, however, to have cheques made out to the name of the payee or order, crossed and marked ’not negotiable’.
The argument of the article is that the form of bank cheques and the wording of some sections in the Cheques and Payment Orders Act places the payee in an invidious position vis-a-vis the drawer, the bank.
"The Form of Bank Cheques,"
Bond Law Review:
2, Article 2.
Available at: http://epublications.bond.edu.au/blr/vol3/iss2/2