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Supreme Court of India 2024-04-10 allowed

PHR INVENT EDUCATIONAL SOCIETY vs UCO BANK AND OTHERS

Bench: 3 — B.R. Gavai, Rajesh Bindal, Sandeep Mehta

In Brief

A borrower who defaulted on a bank loan had mortgaged properties as security. The bank conducted an auction where the appellant (PHR Invent Educational Society) emerged as the highest bidder and paid the full price. The borrower later filed a writ petition challenging the auction after the sale had been confirmed and registered. The Supreme Court held that the High Court erred in entertaining the writ petition because an effective statutory remedy under the SARFAESI Act (appeal to the Debt Recovery Tribunal) was available. The Court emphasized that High Courts ordinarily cannot entertain writ petitions under Article 226 when statutory remedies exist, particularly in bank recovery matters. A confirmed and registered auction sale cannot be interfered with except for fraud or collusion. The appeal was allowed and the writ petition dismissed with costs.

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Securitization and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 Article 226 of the Constitution Writ Petition Alternative Remedy Debt Recovery Tribunal Auction Sale Jurisdiction of High Court Remedies Bank Recovery Law

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