Debt Recovery in India Today: SARFAESI, DRT, Commercial Courts and IBC Sections 7 and 9 Compared

By Bhaskar Subramanian, Partner, S&S Co. Advocates & Solicitors and Chandrayee Roy, Associate, S&S Co. Advocates & Solicitors

Published 24 October 2026 · Law stated as on 22 October 2026 · Informational content, not legal advice: see our disclaimer

A secured lender chasing an unpaid loan in India today can usually choose between four distinct routes to the same money, and the choice is rarely obvious from the loan documents alone. This piece sets out how SARFAESI, the Debts Recovery Tribunals, the ordinary and commercial civil courts, and Sections 7 and 9 of the Insolvency and Bankruptcy Code actually compare, what a guarantor or promoter can expect under each, and where the Supreme Court has moved the ground in 2025 and 2026.

Four routes to the same money

A lender owed money in India by a defaulting borrower is rarely limited to one legal route, and the routes are not interchangeable in what they achieve. A bank or a notified financial institution holding security over immovable or certain movable property can usually proceed under the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002, commonly called SARFAESI, which lets it enforce its security without first obtaining a court decree. The same creditor, or one without SARFAESI-eligible security, can sue before a Debts Recovery Tribunal under the Recovery of Debts and Bankruptcy Act, 1993 (the RDDBFI Act), which gives a decree-granting forum dedicated to bank and financial institution claims above a set threshold. A creditor who is neither a bank nor a notified financial institution, a trade creditor, a landlord, an individual lender, has no access to either of those specialised regimes and must sue in the ordinary civil courts, or in a commercial court where the dispute qualifies as a commercial dispute under the Commercial Courts Act, 2015. And any creditor, financial or operational, holding an undisputed debt above the statutory threshold can instead apply under Section 7 or Section 9 of the Insolvency and Bankruptcy Code, 2016 to put the corporate debtor itself into a resolution process, a route that is not really about individual recovery at all but has become, in practice, one of the most effective pressure points available.

These four routes differ sharply in what they are built to do. SARFAESI and the DRT suit are both aimed squarely at recovering a specific sum from a specific debtor's assets. A civil or commercial court suit does the same thing more slowly but with fewer eligibility restrictions. An IBC application is structurally different: it does not ask for payment to the applicant specifically, but seeks a collective process that may end in resolution, with all creditors sharing in whatever the resolution plan provides, or in liquidation, where the applicant's own claim is paid only according to the waterfall in Section 53. A lender who files under Section 7 expecting a quick path to being paid in full is often disappointed; what the application reliably delivers is pressure, because very few solvent promoters want their company's day-to-day management handed to a resolution professional and its board suspended.

SARFAESI: the self-help route and where it runs out

The mechanics are by now well settled. On classification of an account as a non-performing asset under the RBI's prudential norms, the secured creditor issues a notice under Section 13(2) calling on the borrower to discharge the liability within sixty days. If the borrower does not comply, Section 13(4) lets the creditor take possession of the secured asset, take over its management, or appoint a receiver, without going to court first. Where possession cannot be taken peacefully, Section 14 lets the creditor approach the Chief Metropolitan Magistrate or District Magistrate, whose role courts have consistently treated as ministerial rather than adjudicatory, to secure physical possession with police assistance. A borrower aggrieved by any of this does not have a writ remedy against the bank's action as a general matter; the Act gives a specific, adequate alternative remedy by way of an appeal to the DRT under Section 17, and High Courts have repeatedly declined to entertain writ petitions against Section 13(4) or Section 14 action for that reason, treating the statutory appeal as the route the borrower must use.

Two Supreme Court rulings mark out how far this self-help power now extends. In Celir LLP v Bafna Motors (Mumbai) Pvt Ltd, decided in September 2023, the Court held that the 2016 amendment to Section 13(8) cut off a borrower's right to redeem the mortgaged property at the point the public auction notice is published under Rule 9(1) of the Security Interest (Enforcement) Rules, 2002, displacing the earlier position under which redemption remained open until the sale was actually completed by registration of the certificate and handover of possession. A borrower who wants to save the asset by paying off the dues has, after that ruling, a materially shorter window than many assumed, and timing a settlement offer correctly against the auction notice date has become a live tactical question in every SARFAESI matter that reaches the brink of sale.

In Kotak Mahindra Bank Ltd v Trupti Sanjay Mehta and others, decided on 2 September 2026, the Court addressed a different limit: whether a bank that acquires a non-performing loan from an entity not itself notified as a financial institution under SARFAESI can still invoke the Act against that acquired debt. The Bombay High Court had said no. The Supreme Court reversed, holding that a bank already covered by the Act, which takes over a secured loan originally advanced by a non-notified entity, carries the Act's secured-debt treatment with it, relying on its earlier decisions in M.D. Frozen Foods Exports Pvt Ltd v Hero Fincorp Ltd (2017) and Indiabulls Housing Finance Ltd v Deccan Chronicle Holdings Ltd (2018), and restored the bank's securitisation application before the DRT. For the asset reconstruction and distressed-debt market, where loan books originated by NBFCs and other non-notified lenders are routinely sold to banks and notified ARCs, this closes off what had become a real source of litigation risk at the point of enforcement.

The DRT suit: still necessary, still governed by its own threshold

SARFAESI does not cover every bank debt. A loan without SARFAESI-eligible security, an unsecured overdraft, a personal guarantee standing alone, or security that falls outside the Act's narrower categories (agricultural land remains the most commonly litigated exclusion) still has to be recovered the way the RDDBFI Act contemplated from the start: a suit, called an Original Application, filed before the Debts Recovery Tribunal having territorial jurisdiction, leading to a decree and, on default, a recovery certificate that the Tribunal's Recovery Officer executes much as a civil court executes a decree.

The RDDBFI Act carries its own pecuniary floor. A 2018 notification raised the threshold below which a bank or financial institution cannot approach the DRT at all from ten lakh rupees to twenty lakh rupees, a change the Rajasthan High Court upheld against challenge on the basis that it let the Tribunals concentrate on higher-value matters, and claims below that figure now have to proceed, if at all, in the ordinary civil courts. Delhi High Court authority has also confirmed that an application under Section 13(10) of SARFAESI, through which a secured creditor seeks the balance due after the security proves insufficient, is itself treated as an original application for this purpose, so the same twenty lakh floor governs it.

In practice, the suit route through the DRT remains the forum of choice for recovering against a personal guarantor whose guarantee is unsecured, since a guarantee by itself rarely gives SARFAESI-eligible security, and for recovering the shortfall after a SARFAESI sale has not covered the full outstanding. Lenders who treat SARFAESI as a complete substitute for the DRT suit, rather than as one tool that often needs to be followed by a DRT application for the balance, regularly find themselves with no clean route to the shortfall once the secured asset has been sold. The Original Application procedure itself tracks an ordinary civil suit in most respects, with pleadings, discovery and a final hearing, but it sits before a Tribunal meant to move faster than a crowded civil court list and whose Presiding Officer deals only with bank and financial institution recovery matters; in well-run Tribunals that specialisation does translate into a materially shorter timeline than a comparable suit would take in the district courts, though how far that holds in practice varies considerably from one Tribunal's bench strength and pendency to another's, and a lender should check the particular Tribunal's current pendency before assuming the statutory promise of speed will be delivered in a given case.

Where only the civil or commercial courts will do

A trade creditor, a landlord owed rent, an individual who lent money privately, or any creditor that is not a bank, financial institution, or asset reconstruction company notified under the relevant Acts, has neither SARFAESI nor the DRT available, whatever the size of the claim. For this very large category of creditors, the ordinary civil courts, or the commercial courts where the Commercial Courts Act, 2015 applies, remain the only forum, and the choice within that forum between an ordinary suit and a summary procedure can make a material difference to how quickly a clearly owed debt is actually collected.

Order 37 of the Code of Civil Procedure gives a summary procedure for suits on negotiable instruments, promissory notes, bills of exchange and cheques, and for suits on written contracts for a liquidated sum, where the defendant is not entitled to defend as of right but must apply for leave to defend and show a genuine, triable defence to get it; a defendant who cannot show such a defence faces judgment without a full trial. Where the dispute instead qualifies as a commercial dispute under the Commercial Courts Act, meaning in most states a claim above a threshold of at least three lakh rupees arising from a transaction of a commercial nature, a creditor can apply for summary judgment under Order XIII-A of the Code (as applied to commercial disputes) once summons has been served but before issues are framed, asking the court to decide the claim without recording oral evidence on the footing that the defendant has no real prospect of successfully defending it and no other compelling reason exists for a trial.

Neither summary route is available to every claim; Order 37 does not reach a general money claim unless it fits the categories the rule specifies, and the Order XIII-A summary judgment procedure is unavailable where the suit has itself been filed as an Order 37 summary suit, since the two mechanisms are not meant to be stacked. For creditors outside the banking and financial institution categories, understanding which summary route, if either, actually fits the underlying debt instrument is usually the difference between a judgment within months and a conventional civil suit running for years.

Sections 7 and 9: not recovery, but leverage with teeth

Section 7 lets a financial creditor, one to whom a financial debt is owed, apply to the National Company Law Tribunal for initiation of the corporate insolvency resolution process against a corporate debtor on default, and financial creditors can combine their claims and file jointly to reach the applicable threshold. Section 9 gives an operational creditor, typically a supplier of goods or services, the same right, but without the ability to aggregate claims with other operational creditors; each must independently cross the threshold on its own unpaid invoices, and must first serve a demand notice and wait out the ten-day period during which the corporate debtor can raise a pre-existing dispute, since a genuine dispute recorded before the demand notice defeats the application at the threshold. The default threshold for both routes currently stands at one crore rupees, raised from one lakh rupees during the pandemic specifically to protect small businesses and MSMEs from insolvency applications over comparatively minor defaults, a change that correspondingly made Section 9 far less useful for small operational creditors chasing modest unpaid invoices.

The 2026 amendment to the Code also changed how much certainty a financial creditor has at the admission stage itself, a point this piece addresses only briefly since it is covered at length elsewhere: for several years, following the Supreme Court's reading of the word 'may' in Section 7(5)(a) as conferring discretion on the Adjudicating Authority in Vidarbha Industries Power Ltd v Axis Bank Ltd, an Authority could in principle decline to admit a Section 7 application even where default was established, if the corporate debtor's overall financial health suggested insolvency proceedings were not the right remedy. The 2026 amendment addressed that discretion directly, moving the position back toward near-automatic admission once default and the threshold are shown, which removes a layer of unpredictability financial creditors had been living with since that ruling. Operational creditors under Section 9 continue to face a materially higher bar at admission than financial creditors do, since a recorded pre-existing dispute defeats the application outright, something no equivalent dispute defence interrupts for a financial creditor's claim under Section 7.

Limitation here follows its own settled rule, resolved definitively in B.K. Educational Services Pvt Ltd v Parag Gupta and Associates: Article 137 of the Limitation Act, 1963 applies to Section 7 and Section 9 applications, carrying the general three-year period running from the date of default, and Section 238A of the Code, inserted in 2018, confirmed that the Limitation Act applies to proceedings before the Adjudicating Authority, the NCLAT, the DRT and the DRAT, applied by the Court with retrospective effect to avoid reviving claims that were already time-barred before the Code existed. An application filed more than three years after default is barred unless the delay can be condoned under Section 5 of the Limitation Act, and that condonation power has its own limits; subsequent NCLAT authority has held that a Section 18 acknowledgment of debt, which can extend limitation for an ordinary suit, does not by itself substitute for the separate condonation analysis a CIRP application still has to satisfy.

What an IBC application is genuinely useful for is not usually the money itself; most promoters settle, restructure, or pay up well before a resolution plan is approved, precisely because the consequences of admission, a moratorium on all other proceedings, suspension of the board, and management handed to an independent resolution professional, are severe enough that few are willing to let the process run its course. Lenders who use Section 7 for that leverage, with a realistic plan for what happens if the pressure does not produce a settlement, generally get more out of the provision than those who file expecting it to function like a recovery suit.

Choosing a forum, and the risk of running more than one

The four routes are not mutually exclusive as a matter of law, and creditors frequently run more than one against the same debtor, a SARFAESI action against the secured asset alongside a Section 7 application against the company, or a DRT suit alongside an IBC application once it becomes clear the debtor is genuinely insolvent rather than merely reluctant to pay. The Supreme Court settled a recurring question about this overlap in September 2026 in K.K. Praveen v J.M. Financial Asset Reconstruction Company Pvt Ltd and others, dismissing at the admission stage a borrower's challenge to SARFAESI proceedings on the ground that an earlier DRT decree for the same debt had already merged the cause of action and so barred further action. A bench of Nagarathna and Mahadevan JJ held that Section 35 of SARFAESI, which gives the Act overriding effect over anything inconsistent in any other law, permits a secured creditor to proceed under the Act even where a DRT decree already exists on the same debt, rejecting the argument that res judicata principles stop a creditor from enforcing security after having already obtained a money decree for the underlying debt.

That ruling is good news for lenders who have, for whatever reason, obtained a DRT decree without having first or successfully enforced their security, but it should not be read as removing the practical cost of running parallel proceedings carelessly. A creditor who litigates the same debt in two forums without coordinating the two records the risk of inconsistent findings on quantum, duplicate recovery if neither forum is told what the other has done, and a borrower's objections multiplying across both proceedings rather than being resolved once. The more disciplined approach, and the one courts tend to look on favourably when a borrower complains of harassment through multiplicity of proceedings, is to treat SARFAESI and a DRT suit as sequential: enforce the security first, and pursue the DRT (or, where the shortfall and the debtor's broader insolvency justify it, an IBC application) for whatever remains unrecovered, rather than firing every available mechanism simultaneously from day one.

Guarantors and promoters: liability that survives the principal debtor's troubles

A guarantor's liability under Section 128 of the Indian Contract Act, 1872 is co-extensive with that of the principal debtor unless the guarantee contract itself provides otherwise, and the practical effect is that a creditor does not have to exhaust remedies against the borrower before proceeding against the guarantor; the creditor can usually choose to go after whichever party's assets are easiest to reach first. The Supreme Court confirmed in State Bank of India v V. Ramakrishnan, decided in 2018, that a moratorium under the Code protects only the corporate debtor and does not extend to a personal guarantor, rejecting the NCLAT's contrary view and holding that the guarantor's independent contractual liability survives the moratorium exactly as Section 128 describes it. A guarantor cannot treat a moratorium shielding the principal borrower, or indeed an approved resolution plan under Section 31 that discharges the company's own liability, as discharging their personal guarantee as well; the two liabilities are legally distinct even though they arise from the same underlying debt.

Lenders financing closely held companies routinely take personal guarantees from promoters and directors precisely because the corporate borrower's own assets may prove insufficient or difficult to reach quickly, and a promoter who has signed such a guarantee should assume the lender will pursue them directly, in parallel with or even ahead of action against the company, rather than only after exhausting remedies against the corporate debtor. A corporate guarantee, given by a group company rather than an individual, raises a related but distinct question of corporate authority and benefit, since a guarantee given without proper board approval or without demonstrable commercial benefit to the guarantor company can be challenged by that company's own minority shareholders or, in some circumstances, by its own resolution professional if the guarantor company later enters insolvency itself; lenders taking corporate guarantees from group entities should insist on board resolutions that record the commercial rationale, not merely the guarantee's existence, precisely to foreclose that later challenge.

Personal guarantors have, since 2019, faced their own insolvency process under Part III of the Code, which begins with an interim moratorium on filing of the application under Sections 96 and 95 respectively. That interim moratorium became the subject of a sharp dispute in 2026. The IBC (Amendment) Act, 2026 inserted a new sub-section providing that the interim moratorium shall not apply to a personal guarantor of a corporate debtor with effect from 26 May 2026, but the amendment carried no express saving clause addressing applications already pending on that date, and lenders and guarantors read the silence in opposite directions.

The Bombay High Court resolved the question against guarantors in Tata Capital Financial Services Ltd v Neel Motors LLP and others, decided on 24 July 2026, holding that the statutory language extends to applications already filed, so that the interim moratorium ceased to protect pending personal guarantor applications from the amendment's effective date, alongside future ones; the lender's own application in that matter had been stalled since 2021 precisely because an interim moratorium had come into force against it. A Delhi High Court decision reached the same conclusion roughly a month later, on 19 August 2026, and the Insolvency and Bankruptcy Board of India circulated both rulings to insolvency professionals on 21 September 2026, recording the same position for the parallel provision governing fresh-start applications under Section 124. For promoters and directors who had been relying on a pending application's interim moratorium to keep personal insolvency proceedings paused, this removed that protection with retrospective practical effect, and anyone advising a personal guarantor with a live application should treat the moratorium as no longer available regardless of when the application was filed.

Limitation and the other traps that decide cases before the merits do

Limitation defeats more recovery actions on technical grounds than any substantive defence does, and the rules differ meaningfully across the four routes. A DRT suit, like an ordinary money suit, generally runs on the three-year period under Article 137 (or the more specific articles governing suits on particular instruments) from when the right to sue accrues, extendable where the borrower has made a written acknowledgment of the debt under Section 18 of the Limitation Act, something balance confirmation certificates and loan restructuring correspondence are frequently relied on to establish; an acknowledgment must be made before the original limitation period expires, since an acknowledgment given after the debt has already gone time-barred does not revive a dead claim. An IBC application under Section 7 or 9 runs on the same three-year Article 137 period from default, as B.K. Educational Services settled, and an acknowledgment of debt can similarly extend that period, though the NCLAT has been clear that it is not interchangeable with the separate Section 5 condonation analysis that applies once the application is actually filed out of time.

A second recurring trap concerns the move from a DRT decree to a recovery certificate and, in some cases, onward to an IBC application. Where a lender holds a long-standing recovery certificate issued before the Code's insolvency framework for financial creditors matured into its current form, the question of whether and how that certificate can found a fresh Section 7 application, as opposed to simply being executed through the Recovery Officer's own powers, has generated real litigation, and lenders holding old recovery certificates should treat the choice between execution and a fresh insolvency application as one that needs specific legal advice on the facts of the certificate's date and terms, rather than an assumption that either route is automatically open.

The third trap sits in compliance rather than procedure: a bank's own internal process in classifying an account as a non-performing asset, tagging it as fraud, or declaring a borrower a wilful defaulter must itself follow the RBI's master directions, including a reasoned order and, for a fraud or wilful defaulter tag, a proper show-cause process satisfying natural justice. High Courts have quashed fraud classifications and wilful defaulter tags passed without adequate reasoning or without giving the borrower a genuine opportunity to respond, and a recovery action built on a defectively classified account risks being unwound at exactly the moment enforcement reaches its sharpest point, so lenders are better served checking that these internal classifications will withstand scrutiny before relying on them as the trigger for SARFAESI or an IBC application, rather than discovering the gap only when a court is asked to stay enforcement.

A sequencing checklist in prose

A lender deciding how to pursue a defaulting borrower is better served working through the decision in a fixed order than picking a forum by habit. Begin with the security: if the debt is secured by an asset that falls within SARFAESI's reach and the creditor is a bank, financial institution or notified ARC, the self-help route is almost always faster than a suit and should ordinarily be exhausted first, with the Section 13(2) notice period and the Section 13(8) redemption cutoff both timed carefully against any settlement discussion, since an offer that arrives after the auction notice is published no longer has the same leverage it would have had earlier. Move next to the shortfall question: once the security is sold, calculate whether the proceeds cover the outstanding debt, and if not, have the DRT application for the balance ready to file rather than treating the SARFAESI sale as the end of the recovery effort. Where there is no SARFAESI-eligible security at all, whether because the debt is an unsecured guarantee, an overdraft, or a loan secured only by property outside the Act's categories, go straight to the DRT suit if the twenty lakh threshold is met, and to the ordinary or commercial civil courts, with the Order 37 or Order XIII-A summary route considered specifically, if it is not or if the creditor is not a bank or financial institution at all.

Reserve an IBC application for the cases where the underlying problem is the debtor's genuine inability to pay rather than simple reluctance, and where the creditor is prepared to accept the collective, non-recovery-specific nature of what a resolution process actually delivers; filing Section 7 or Section 9 as a pure pressure tactic against a company that can clearly pay but is choosing not to can work, since few promoters want a resolution professional running their company, but it should be done with a clear view of what happens if the pressure fails and the process runs its course, because at that point the applicant becomes one creditor among many rather than someone with a specific decree to execute. Throughout, track limitation independently of whichever forum is chosen, since a written acknowledgment taken at the right time, before any period has run out, is one of the cheapest and most reliable ways to protect a claim that might otherwise be fought years later on a technical time-bar rather than on its merits.

A guarantor or promoter served with proceedings should work through a parallel sequence: confirm whether the guarantee is secured or unsecured, since that determines whether SARFAESI can reach the guarantor's own assets directly or whether the creditor is confined to a DRT or civil suit against the guarantor personally; check whether any moratorium the principal borrower enjoys, corporate or personal, is being wrongly assumed to extend to the guarantor, since on current authority it almost never does; and, where a personal insolvency application is already pending, assume from 26 May 2026 onward that no interim moratorium protects it, regardless of the filing date, and plan accordingly rather than relying on a protection the Bombay and Delhi High Courts have both held no longer exists for pending matters.

What remains unsettled

Several points in this area have not yet settled into a single, confirmed answer. Whether the bench that decided Tata Capital Financial Services Ltd v Neel Motors LLP sat as a division bench or a single judge could not be confirmed with confidence from the sources available for this piece, and that detail, along with the exact paragraph reasoning on retrospective operation, is worth checking against the reported judgment (2026 SCC OnLine Bom 11090, as cited in secondary commentary) before it is relied on in a specific matter, since an appeal or a contrary ruling from another High Court could still emerge given how recently the question was decided.

The precise relationship between an old, pre-2016-framework DRT recovery certificate and a fresh Section 7 application against the same debtor is an area this piece has deliberately treated with caution, since the available research did not yield a clearly verified Supreme Court ruling settling the point with a confirmed case name and citation, notwithstanding reporting on related disputes; a lender holding such a certificate should get a dedicated opinion on its specific facts rather than assuming either route, execution or a fresh insolvency application, is automatically open. Finally, how aggressively the Section 5 condonation power will be used to rescue IBC applications that miss the three-year Article 137 window, particularly where an acknowledgment of debt sits close to the boundary of the original limitation period, remains a fact-sensitive question on which NCLAT and High Court authority continues to develop rather than having settled into a single predictable test.

None of these four routes has made the others redundant, and that is probably the most useful single fact to take from the current state of the law. SARFAESI remains the fastest way to reach secured collateral, the DRT suit remains the necessary fallback for whatever SARFAESI cannot reach, the civil and commercial courts remain the only option for creditors outside the banking and financial institution categories, and an IBC application remains a genuinely different instrument, more a lever on a reluctant promoter than a recovery mechanism in its own right.

What has changed through 2025 and 2026 is less the structure of these routes than the certainty around their edges: how much redemption time a borrower really has before a SARFAESI sale, whether an assigned NBFC loan still carries SARFAESI eligibility, whether a DRT decree closes off a later SARFAESI action, and whether a personal guarantor's pending insolvency application still enjoys an interim moratorium. Each of those questions has now been answered, mostly in the creditor's favour, and a lender or a guarantor working from last year's assumptions about any of them is working from a position the courts have already moved past.

Frequently Asked Questions

References & Further Reading

The provisions, rulings and official documents below were relied on for this article, which states the law as on 22 October 2026. The position can change with amendments, rules and later decisions, so check the current text before acting on any of it.

1. Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002, Sections 13(2), 13(4), 13(8), 13(10), 14, 17, 35
2. Security Interest (Enforcement) Rules, 2002, Rule 9
3. Recovery of Debts and Bankruptcy Act, 1993, Section 1(4) and pecuniary limit notifications (2018)
4. Code of Civil Procedure, 1908, Order 37 (summary suits) and Order XIII-A (summary judgment in commercial disputes)
5. Commercial Courts Act, 2015, Section 3
6. Insolvency and Bankruptcy Code, 2016, Sections 4, 5, 7, 9, 53, 95, 96, 124, 238A
7. IBC (Amendment) Act, 2026 (Sections 96(4) and 124(4) on cessation of interim moratorium for personal guarantors, effective 26 May 2026; also addressing the admission-stage discretion issue raised in Vidarbha Industries Power Ltd v Axis Bank Ltd)
8. Vidarbha Industries Power Ltd v Axis Bank Ltd, Supreme Court (2022), on the discretionary reading of Section 7(5)(a)
9. Indian Contract Act, 1872, Section 128
10. Limitation Act, 1963, Articles 137 and Section 18
11. Celir LLP v Bafna Motors (Mumbai) Pvt Ltd, Supreme Court, decided 21 September 2023
12. Kotak Mahindra Bank Ltd v Trupti Sanjay Mehta and others, Supreme Court, decided 2 September 2026 (2026 INSC 943 / 2026 LiveLaw (SC) 886)
13. K.K. Praveen v J.M. Financial Asset Reconstruction Company Pvt Ltd and others, Supreme Court, W.P. (Civil) No. 1091/2026, order dated 9 September 2026
14. M.D. Frozen Foods Exports Pvt Ltd v Hero Fincorp Ltd, Supreme Court (2017)
15. Indiabulls Housing Finance Ltd v Deccan Chronicle Holdings Ltd, Supreme Court (2018)
16. State Bank of India v V. Ramakrishnan, Supreme Court (2018)
17. B.K. Educational Services Pvt Ltd v Parag Gupta and Associates, Supreme Court, AIR 2018 SC 5601 / (2019) 11 SCC 633
18. Tata Capital Financial Services Ltd v Neel Motors LLP and others, Bombay High Court, decided 24 July 2026 (2026 SCC OnLine Bom 11090, as cited in secondary commentary)
19. Delhi High Court ruling on Section 96(4) applicability to pending applications, 19 August 2026
20. IBBI Circular No. IBBI/II/106/2026, dated 21 September 2026
21. United Bank of India v Satyawati Tondon, Supreme Court (on the alternative remedy bar to writ petitions against SARFAESI action)

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