Breaking Supreme Court Legal Update
New Delhi · Sunday, 02 August 2026 9888666310 | [email protected]
Free Law — free judgments and free headnotes Free Lawby De Jure
Supreme Court of India 2021-12-06 dismissed

Akshay N Patel vs Reserve Bank of India & Anr

Bench: 3 — Dhananjaya Y Chandrachud, Vikram Nath, B V Nagarathna

In Brief

Akshay Patel, an Indian entrepreneur engaged in merchanting trade transactions (MTTs), challenged RBI's prohibition on MTTs for PPE products under the Revised 2020 MTT Guidelines. The goods in MTTs transit between foreign countries with India acting as intermediary. The RBI linked MTT permissibility to India's Foreign Trade Policy, which banned PPE exports during COVID-19. The Supreme Court upheld the prohibition using a four-pronged proportionality test: the measure served the legitimate aim of securing adequate domestic PPE supplies; was suitable because MTTs affect India's foreign exchange reserves similarly to traditional trade; was necessary to prevent foreign hoarding of supplies; and was not disproportionate. The Court emphasized that fundamental rights cannot become weapons to disable public-interest regulations, and that the RBI's expert regulatory decisions warrant circumspect deference within constitutional bounds.

The lawyer headnote and full judgment text are available to registered users.

Constitutional Law Foreign Exchange Trade Regulation Fundamental Rights Proportionality Administrative Law Public Health COVID-19

Read the full judgment & headnote. It's free.

Register to read the complete Supreme Court judgment text and the headnote, and to search 1 lakh+ Supreme Court judgments by meaning. It is a free service.

Register Free Login