Explanation:

- Promissory Note: A promissory note is a written promise to pay a specified sum of money to a certain person or bearer. However, it is generally not considered a bearer instrument because it specifies a payee.

- Bill of Exchange: A bill of exchange can be a bearer instrument if it is made payable to the bearer (e.g., “pay to the order of bearer”).

- Cheque: A cheque can also operate as a bearer instrument if it states “pay to bearer.”

- None of the above: This implies that none of the listed instruments can be bearer instruments, which is not the case here.

The correct answer is:

- ?? Promissory Note cannot be a bearer instrument.