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Supreme Court of India 2019-09-23 allowed

THE AUTHORIZED OFFICER,INDIAN BANK vs D. VISALAKSHI

Bench: 2 — A.M. Khanwilkar, Dinesh Maheshwari

In Brief

This landmark judgment resolves a conflict between high courts on whether Chief Judicial Magistrates (CJMs) in non-metropolitan areas can process secured creditors' applications to take possession of secured assets under the Securitisation and Reconstruction of Financial Assets Act, 2002. The Supreme Court held that CJMs are equally competent as Chief Metropolitan Magistrates and District Magistrates to do so. The Court reasoned that the inquiry under Section 14 is administrative, not adjudicatory, and CJMs exercise equivalent functions to CMMs under the Criminal Procedure Code. This purposive interpretation furthers speedy debt recovery while preserving borrowers' statutory appeal rights and judicial review. The decision approves High Court decisions from Kerala, Karnataka, Allahabad, and Andhra Pradesh and reverses contrary views from Bombay, Calcutta, Madras, Madhya Pradesh, and Uttarakhand.

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Banking and Finance Debt Recovery Securitisation Secured Lending Criminal Procedure Statutory Interpretation Administrative Law Judicial Review

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