if he refuses to pay he would be convicted of offence under section 138 Ni and would be sentenced to imprisonment 

if you have to pay him for earlier work he can claim payment form you 

2) file suit to recover money due and payable by you 

Hi,

This is not a valid defense. He should have informed you regarding this. However, on the basis of your past relationship, you may grant him time by undertaking on his part to make payments.

NO escape, he literally admitted the payment due. Good for your case.

NO.

You almost win the case.

No that is not right defence , he owe you legal debt for same he has issued the cheque he cannot take such defence before the court.

See primarily it was upon you to establish you case now you have done that by mere saying he cannot take defence he need proof of same.

No this is not right as he has issued the check it is his responsibility to pay the amount as per the cheque.

you have to prove in the code that he has the outstanding and was liable to pay the amount

No, he can not escape by saying so 

No. 

You will have to show that the payment was for some legally enforceable debt and that the same has not been done in the present case. 

Regards 

1. loss of business is no answer to disclaim a liability under the cheque for which it was issued in first place

2. the defendant's burden does not get discharged by asserting as above

3. the defendant also cannot seek any set off against the cheque amount by claiming payments for previous work

4. the cheque transaction is distinct and independent and cannot be mixed with past transactions

On the dishonour of a cheque, one can file a suit for recovery of the cheque amount along with the cost and interest under order XXXVII of Code of Civil Procedure 1908 ( which is a summary procedure and) can also file a Criminal Complaint us 138 of Negotiable Instrument Act for punishment to the signatory of the cheque for haring committed an offence

drawer cannot escape from his responsibility. 

No he can't escape by saying that. You can seek attachment of the property to seek the previous condition

If you prove that the cheque issued against the money (debt) payable to you, you will succeed.

He cannot claim set off with other work.

He cannot escape the liability on this ground.

Since he has issued cheque then it becomes his responsibility to settle the amount or face the charges leveled against him in the court of law.

Let him claim anything in any manner, you can concentrate on your case by producing yor side evidence with the support of documentary evidences and merits in your side to properly prosecute the case against him.

No he cannot escape the liability on ground of losses in business. 

He have to pay the dues for which he have issued the cheque.