There are different standpoints about method of calculation of delayed payment penalty of checque. This is because of governing and applying different laws in this field. According to article 2 of checque insurance Act, date of checque is the beginning of calculation but article 522 of Civil Procedure Act provides for that for calculation of this loss, date of demanding is of significance. Regarding this conflict, some courts decide that date of payment (mentioned in checque insurance Act) is the very usual. Some courts belive that the date of notice of non- payment is relevant. In some judicial decisions, the date of bringing an action is the criterion. In relation to the statute of limitation about checques, another precedent governs.