In this case, A issued to B on July 15, 1993 five promissory notes with the place of issue left blank, with a total face value of 220,000,000 won; B endorsed and transferred them to Y, and all of them were then endorsed and transferred to X, who became the final holder of all the notes. On October 30, 1993, X presented the notes for payment at the place of payment without filling in the place of issue, but payment was refused. X sought to exercise the right of recourse against Y, but Y argued that because X presented the notes without filling in the place of issue, the presentment was improper and X lost the right of recourse against Y as endorser. If X sues Y, X's claim can be upheld. The notes in this case are clearly domestic notes issued and paid in Korea, so they cannot be treated as invalid even though no place of issue appears on their face, and even though they were presented without a place of issue, the presentment should be regarded as proper.

The en banc decision is an important precedent that denied the place of issue the status of a formal requirement for notes used within Korea. The majority opinion reasons that the place of issue is an important standard for interpreting acts on international notes but has little meaning for domestic notes, and lists criteria for domestic notes that are valid without a place of issue. Under those criteria, the place of payment or paying location is in Korea, the issuer and payee are Korean, the amount is stated in won, the wording of the note is written in Korean or Chinese characters, and the name of the clearing house is in Korea. Whether all these criteria are reasonable is questionable, and they could be read as recognizing domestic notes only for promissory notes, because they say nothing about the drawee or acceptor.

In this respect, the court should have made clear why a bill of exchange cannot be a domestic note. On the premise that domestic notes are limited to promissory notes, if a blank note bearing only an endorsement and no formal requirements at all is issued and the place of issue is never filled in, the note's fate would be that it becomes valid if all requirements later fit the criteria in this decision and invalid if even one is missing, which would rather harm the security of transactions. On the criteria for domestic notes, there is criticism that "as the domestic market opens further and the currencies of major countries circulate freely in Korea, disputes are expected over whether a note is domestic.

To add: this en banc decision overruled earlier cases that treated notes without a place of issue as invalid. Where the paper cites "Article 1(7) and Article 75(6) of the Bills of Exchange and Promissory Notes Act," the correct references are items 7 and 6 of those articles. After the decision, the Act on the Issuance and Distribution of Electronic Promissory Notes was enacted in 2004 and took effect in 2005, and as the use of notes declined, the government has pursued a policy of gradually phasing down paper promissory notes. The right of recourse on bills and promissory notes can be exercised only after proper presentment for payment and refusal (Articles 43 and 77).