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Supreme Court of India 2022-07-27 dismissed

M/s R.D. Jain and Co vs Capital First Ltd. & Ors

Bench: 2 — M.R. Shah, B.V. Nagarathna

In Brief

The Supreme Court upheld a High Court ruling that Additional Chief Metropolitan Magistrates and Additional District Magistrates can exercise powers under Section 14 of the SARFAESI Act (which involves taking possession of secured assets in loan recovery cases). The Court held that these magistrates are not persona designata (specifically named individuals) for these purposes. Since the powers involved are purely ministerial in nature—merely taking possession after verifying statutory compliance—not adjudicatory, and given the large volume of pending applications that must be disposed of within 30–60 days, a purposive interpretation allows subordinate magistrates of equivalent rank to exercise these powers. The Court overruled contrary decisions from Gujarat, Calcutta, and Kerala High Courts.

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Securitisation and Reconstruction of Financial Assets Enforcement of Security Interest Administrative Law Magistracy Statutory Interpretation Asset Recovery

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