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Supreme Court of India 2022-05-18 dismissed

Indian Overseas Bank vs RCM Infrastructure Ltd. and Another

Bench: 2 — B.R. Gavai

In Brief

A bank initiated enforcement proceedings under the SARFAESI Act against a corporate debtor that had defaulted on a secured loan. After the bank confirmed the sale of mortgaged assets with partial payment, the corporate debtor filed for insolvency, triggering a moratorium. The Supreme Court held that the moratorium under IBC Section 14(1)(c) prohibits all security enforcement actions—including SARFAESI proceedings—once insolvency commences. The statutory sale under SARFAESI is completed only upon full payment and issuance of a sale certificate, not merely upon confirmation with partial payment. Since full payment occurred after insolvency began, the sale was set aside as prohibited.

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Insolvency and Bankruptcy Code Moratorium Secured Creditors SARFAESI Act Statutory Sale Corporate Insolvency Resolution Process

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