Recovery and Insolvency for Lenders and Borrowers in Noida: SARFAESI, the DRT, Cheque Cases and the Right NCLT Bench

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

Published 28 October 2026 · Law stated as on 26 October 2026 · Informational content, not legal advice: see our disclaimer

A loan default involving a borrower or secured asset in Gautam Buddh Nagar can be pursued through at least four separate forums, SARFAESI enforcement, a suit before the Debts Recovery Tribunal, a cheque-dishonour complaint, or an insolvency petition before the NCLT, and each one sits in a different tribunal with its own district allocation and its own procedural traps. This piece sets out what is actually settled about which forum sits where for Noida and the districts around it, and flags the points that genuinely are not yet settled.

Why the forum decides the outcome here

Gautam Buddh Nagar sits in an unusual position on the recovery map of India. It is a Uttar Pradesh district governed by UP's tribunal and court structure, yet it borders Delhi closely enough that lenders, borrowers and even some practitioners default to assuming Delhi's forums apply. That assumption causes real problems. Filing a SARFAESI appeal or a recovery suit in the wrong tribunal does not simply get transferred without cost: it can consume the limitation period, require the application to be refiled, and in some cases let a defaulting borrower raise a maintainability objection that delays enforcement by months.

This piece works through four recovery routes a lender dealing with a Noida or wider western UP default is likely to need, SARFAESI enforcement against secured assets, a Debts Recovery Tribunal suit or Section 17 application, a Section 138 cheque-dishonour prosecution, and an insolvency petition before the National Company Law Tribunal, and sets out what is actually confirmed about jurisdiction for each, rather than repeating assumptions that have not been tested against the governing notifications and case law.

SARFAESI enforcement: the mechanics stay the same, the forum does not

The Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 lets a secured creditor enforce its security without first obtaining a court decree, provided the asset qualifies and the loan has been classified as a non-performing asset under the Reserve Bank of India's prudential norms. The process begins with a notice under Section 13(2), demanding repayment within sixty days, and if the borrower does not comply, the creditor may take possession of the secured asset under Section 13(4), with the District Magistrate empowered under Section 14 to assist with physical possession where the borrower resists. For an asset in Gautam Buddh Nagar, that application for assistance goes to the District Magistrate of Gautam Buddh Nagar, and the process at this stage does not differ from a SARFAESI action anywhere else in the country.

The point where Noida's geography actually matters is not the Section 13 or Section 14 stage, both of which are district-administration functions tied unambiguously to where the asset sits, but the appellate stage under Section 17, where a borrower challenges the creditor's measures before the Debts Recovery Tribunal. The Act gives jurisdiction to the DRT within whose local limits the secured asset is located, but the Allahabad High Court has clarified, in Ram Pal Soni versus State of U.P., decided in 2024, that this is not the only basis on which jurisdiction can rest: a DRT in whose jurisdiction any part of the cause of action has arisen, which can include the borrower's place of residence or business, or the branch that sanctioned and disbursed the loan, can also properly hear the Section 17 application. For a Noida transaction where the asset, the borrower and the lending branch do not all sit in the same tribunal's territory, which happens often enough given how many NBFC and bank branches serving Noida borrowers are themselves based in Delhi, this ruling widens rather than narrows the range of DRTs that can validly hear the dispute, and a lender should plead the full factual basis for jurisdiction, not just the asset's location, to avoid a maintainability fight later.

Once possession is secured, the sale of the asset itself proceeds under Security Interest (Enforcement) Rules, 2002, principally Rule 9, which sets out the mechanics a secured creditor must follow: a reserve price fixed before the sale, a notice period of at least thirty days published both to the borrower and generally in newspapers, and a requirement that the earnest money and the balance consideration be paid within strict, short windows after the auction closes, failing which the sale can be set aside and the deposit forfeited. Lenders enforcing against a Noida property have, in practice, as much to lose from a Rule 9 shortcut, an inadequate reserve price, a defective notice, or an irregular timeline for payment, as from any jurisdictional defect, since a sale set aside for a Rule 9 breach sends the creditor back to the start of the enforcement process with the clock on recovery reset entirely. A careful lender treats Rule 9 compliance as a discipline to document contemporaneously, not a formality to assume has been followed.

Which DRT actually covers Gautam Buddh Nagar

Territorial jurisdiction of the Debts Recovery Tribunals is fixed by central government notification under Section 3 of the Recovery of Debts and Bankruptcy Act, 1993, not by the Act itself, and those notifications are amended from time to time as new tribunals are added. What is confirmed from an Allahabad High Court headnote is that a 2017 central notification assigned the DRT at Allahabad jurisdiction over fifty-five districts of Uttar Pradesh. Separately, commentary from practitioner sources, which should be treated as indicative rather than authoritative, describes a cluster of western UP districts closer to Delhi, including Meerut, Hapur, Ghaziabad, Muzaffarnagar and Saharanpur, as falling under a Delhi-based DRT rather than Allahabad.

Gautam Buddh Nagar is not named in either list in the sources available, which leaves its precise allocation unconfirmed from this research. Given that it is not among the western districts the Delhi-DRT commentary names, and given the breadth of the fifty-five-district notification covering DRT Allahabad, the more likely position is that Gautam Buddh Nagar falls within DRT Allahabad's jurisdiction, but this is an inference from the pattern of the other districts, not a confirmed fact, and a lender or borrower should verify the current position against the Department of Financial Services' gazette notifications, or by checking directly with the DRT registry, before filing. This is one of the clearest instances in this area where confirming jurisdiction before filing is not a formality but a genuine, unresolved question worth the cost of checking properly.

A further complication sits above the district-allocation question. In October 2022, the central government issued notifications redistributing pecuniary jurisdiction so that DRT matters above one hundred crore rupees would be concentrated at the tribunals in Delhi, Chennai and Mumbai, regardless of the usual territorial allocation. The Bombay High Court's Aurangabad bench stayed that notification, holding that divesting a DRT of jurisdiction it holds under the Act itself cannot be done by executive notification without amending the Act. The current operative status of that stay, and whether the pecuniary reallocation has since been reinstated, modified or abandoned, could not be confirmed from the sources available, so a lender with a claim above that threshold against a Noida-based borrower should check the position afresh before assuming either the old or the new allocation applies.

DRAT Allahabad and the appeal from a DRT order

An order of the Debts Recovery Tribunal, whether in a Section 17 SARFAESI matter or in an original recovery suit under Section 19 of the 1993 Act, is appealable to the Debts Recovery Appellate Tribunal, which for the Allahabad DRT sits at Prayagraj. The appellate tribunal's functioning has itself been a live concern: the Allahabad High Court, in a 2025 order, recorded its alarm at vacancies affecting the tribunal and urged the central government to expedite appointments, noting that the tribunal was not functioning for want of a member being appointed. A lender or borrower planning an appeal should check the current staffing position at DRAT Allahabad before assuming a hearing date will be available on the usual timeline, since an unstaffed bench can add months of delay that has nothing to do with the merits of the underlying case.

Section 18 of the SARFAESI Act requires a borrower appealing against a DRT order under Section 17 to deposit a percentage of the amount due, generally fifty per cent, with the tribunal having discretion to reduce this to not less than twenty-five per cent for reasons recorded in writing, a structure that mirrors the pre-deposit condition RERA imposes on a promoter's appeal and exists for the same reason: to filter out appeals filed only to delay enforcement, while leaving a genuine route open for a borrower who disputes the recovery on substantial grounds and can show cause for a reduced deposit.

The DRT suit route under Section 19 and when it still matters

Where the secured creditor does not want to or cannot proceed by SARFAESI, perhaps because the security is incomplete, defective, or the asset does not qualify for the Act's self-help remedy, a suit for recovery of debt can still be filed directly with the Debts Recovery Tribunal under Section 19 of the 1993 Act, provided the amount claimed exceeds the pecuniary threshold the Act sets, raised in 2018 from ten lakh rupees to twenty lakh rupees. This route produces a Recovery Certificate once the DRT decides the matter, which is then executed by the tribunal's own Recovery Officer using powers broadly equivalent to those available to a civil court executing a decree, including attachment and sale of the debtor's property.

A lender holding both a security interest that could support SARFAESI action and a personal guarantee or unsecured exposure that cannot should not assume these routes are mutually exclusive, but should also be alive to how an outcome in one forum can affect the other. The Supreme Court has held that losing a SARFAESI challenge before the DRT bars a borrower from relitigating the identical grievance in a civil suit, on the principle that the earlier forum's finding operates as res judicata, a point the Kerala High Court applied directly in a 2026 matter involving IFCI's SARFAESI action against a hotel property. The same logic cuts both ways: a creditor that loses a Section 17 challenge on a point going to the validity of its security should expect that finding to follow it into a parallel Section 19 suit or any later IBC application resting on the same security.

Assigned debt, ARCs and the borrower protections courts have carved out

A substantial share of the retail and MSME lending originated in the Noida market over the past decade now sits with asset reconstruction companies or has been assigned between a bank and an NBFC rather than held by the original lender, and borrowers facing enforcement on assigned debt have sometimes argued that the assignee cannot invoke SARFAESI at all. The Supreme Court closed off one version of that argument in a ruling involving Kotak Mahindra Bank, holding that a bank can invoke SARFAESI on a debt it acquired by assignment from an NBFC even though the NBFC itself was not, at the relevant time, a secured creditor covered by the Act, because the Act's benefit attaches to the assignee bank's own status as a secured creditor at the point of enforcement, not to the assignor's status at origination. A borrower in Noida who took a loan from an NBFC that later sold the receivable to a bank or an asset reconstruction company cannot resist enforcement merely by pointing to the original lender's identity.

Two further protections have emerged from recent rulings that a Noida borrower facing SARFAESI action should know apply regardless of the lender's identity. The Supreme Court has held that a SARFAESI auction sale is not final until the balance consideration is actually paid, and that a borrower retains the right to redeem the mortgaged property in the gap between the auction and full payment, a point of real practical value to a borrower who can arrange funds after an auction has been conducted but before it has been completed. Separately, the Punjab and Haryana High Court has stayed dispossession from a borrower's sole residential house in a SARFAESI recovery where the underlying debt was below twenty lakh rupees, a ruling that, while not from a court with direct jurisdiction over Uttar Pradesh, reflects a judicial trend toward scrutinising enforcement against a family's only home more closely where the amount at stake is modest, and a borrower in a comparable position in Gautam Buddh Nagar would have a reasonable basis to raise the same argument before the local DRT even though the point has not yet been tested there directly.

A related and frequently overlooked point concerns guarantors. Where a bank has recovered part of a defaulted amount from a guarantor who then seeks to recover that sum from the principal borrower, the guarantor steps into the bank's shoes by subrogation and can pursue the borrower using largely the same recovery tools, including, where the guarantor is itself a financial institution, a DRT suit. A Noida-based guarantor who has paid out under a guarantee should treat that payment as the trigger for its own recovery action against the borrower, rather than treating the loss as absorbed and final, since the right of subrogation survives the original loan transaction independently of whatever recovery route the original lender chose.

Commercial Courts, civil suits and the limits of DRT jurisdiction

Not every lending dispute belongs before the DRT even where the amount crosses the pecuniary threshold. The Debts Recovery Tribunal's jurisdiction is confined to claims by banks and specified financial institutions against borrowers for recovery of debt, and a dispute that does not fit that description, a breach of a loan covenant that does not yet amount to a debt recovery claim, a dispute over the validity of a security document between parties who are not within the Act's defined categories, or a claim by a borrower against a lender rather than the other way around, generally falls to the ordinary civil courts, and in Gautam Buddh Nagar that increasingly means the Commercial Courts Act, 2015 structure where the claim qualifies as a commercial dispute above the specified value, with its own pre-institution mediation requirement under Section 12A and its tighter case-management timelines.

This distinction matters in practice because borrowers facing SARFAESI or DRT action sometimes attempt to file a parallel civil suit challenging the loan documentation itself, hoping an injunction from a civil court will stall the DRT process. Courts have generally resisted this, holding that where the DRT has jurisdiction to decide the very question the civil suit raises, Section 34 of the SARFAESI Act and the parallel bar under the 1993 Act operate to keep the matter within the tribunal system, leaving civil court intervention available only in narrow circumstances, such as a genuine challenge to the existence of the debt itself rather than to the manner of its enforcement.

Insolvency against the corporate debtor: the NCLT Allahabad Bench

Where recovery against a company registered in Noida, Greater Noida, Ghaziabad or anywhere else in Uttar Pradesh requires corporate insolvency proceedings, whether initiated by a financial creditor under Section 7 of the Insolvency and Bankruptcy Code, 2016, an operational creditor under Section 9, or the corporate debtor itself under Section 10, the correct forum is the National Company Law Tribunal's Allahabad Bench. This is confirmed from two independent sources: the tribunal's own current jurisdiction table, published on nclt.gov.in, lists the Allahabad Bench as covering the State of Uttar Pradesh and the State of Uttarakhand, and this is corroborated by independent legal commentary tracing the same allocation, including the 2017 gazette notification that moved Haryana's jurisdiction to the Chandigarh Bench, which by implication confirms Uttar Pradesh, unaffected by that transfer, remained with Allahabad.

This produces a result some lenders and practitioners in the National Capital Region find counterintuitive: a company with its registered office in Gurugram falls under the Chandigarh Bench because Gurugram sits in Haryana, while a company with its registered office in Noida, Greater Noida or Ghaziabad, despite being functionally part of the same NCR business district and often sharing clients, suppliers and even office parks with Gurugram companies, falls under the Allahabad Bench because those cities sit in Uttar Pradesh. Jurisdiction under the Code follows the registered office recorded with the Registrar of Companies, not the city's economic integration with Delhi, and a creditor who assumes an NCR company's insolvency petition belongs at NCLT New Delhi because that is where its business is actually conducted will find the petition is in the wrong forum if the registered office is, as is common for UP-incorporated subsidiaries of NCR groups, in a UP district.

A separate practical point concerns the Allahabad Bench's own capacity. The Allahabad High Court has, in a different matter, issued notice to the central government on a plea to establish a regional bench of the National Company Law Appellate Tribunal at Allahabad, reflecting a broader concern about the distance insolvency litigants in UP must travel for appellate relief, since NCLAT currently sits at New Delhi for matters arising from the Allahabad Bench. A creditor planning the timeline for an insolvency petition and any likely appeal should factor this distance and the appellate tribunal's own caseload into its expectations, rather than assuming the proximity of Noida to Delhi will translate into proximity to the appellate forum.

Personal guarantors and the bench that actually has jurisdiction over them

A guarantor who has given a personal guarantee for a loan to a Noida-based company and is pursued under Part III of the Insolvency and Bankruptcy Code, which governs insolvency resolution and bankruptcy for individuals including personal guarantors, does not get to choose, or default to, the NCLT bench nearest their own residence. The National Company Law Appellate Tribunal has confirmed that a personal guarantor's insolvency application must be filed at the NCLT bench that is already seized of, or has already decided, the corporate debtor's own corporate insolvency resolution process, so that both proceedings, against the principal borrower and against the guarantor, are heard by the same bench. For a guarantor who lives outside Uttar Pradesh but has guaranteed a loan to a company registered in Noida or Greater Noida, this means the guarantor's own insolvency proceeding, despite concerning their personal assets wherever those happen to be located, is heard at NCLT Allahabad because that is where the corporate debtor's case sits.

This bench-linkage rule has a converse effect lenders should plan around: a bank pursuing a personal guarantor separately from, or ahead of, action against the principal borrower cannot assume it has a free choice of forum simply because the guarantor resides elsewhere; the rule fixes the forum to the corporate debtor's bench regardless of sequencing, and a creditor who files the guarantor application in the wrong bench on the assumption that the guarantor's residence controls risks the same maintainability delay that misfiling causes at the DRT stage.

Cheque-dishonour complaints: the payee's bank branch, and an unsettled procedural fight

A Section 138 complaint for a dishonoured cheque is a frequent companion to a loan default in Noida, whether the cheque was given as repayment security or as part of settlement negotiations that later broke down. The Negotiable Instruments (Amendment) Act, 2015, which inserted Section 142(2) with effect from 26 December 2015, settled what had been a genuinely confused area of law before it: jurisdiction now rests, under clause (a), with the court where the branch of the payee's or holder's bank account is located, where the cheque was delivered for collection through an account, and under clause (b), with the court where the drawee bank's branch is located, where the cheque is presented for payment otherwise than through an account. An explanation to the provision deems a cheque delivered at any branch of the payee's bank as delivered at the branch where the payee actually holds the account, closing off an earlier practice of presenting cheques at a convenient branch purely to manufacture jurisdiction.

For a Noida-based lender or business that presents a dishonoured cheque through its own bank account held at a branch in Gautam Buddh Nagar, this means the Section 138 complaint can be filed at a court in Gautam Buddh Nagar regardless of where the drawer or the drawee bank is located, a position the Supreme Court has reaffirmed as recently as November 2025, holding that jurisdiction over an account-payee cheque lies with the court where the payee's own account-holding branch sits. The earlier position under Dashrath Rupsingh Rathod versus State of Maharashtra, which the Supreme Court decided in 2014 and which tied jurisdiction instead to the drawee bank's branch, no longer controls for cheques covered by the 2015 amendment, though that 2014 ruling's own prospective-only effect means it can still govern cases that were already at an advanced procedural stage when the amendment took effect.

A live and genuinely unsettled procedural question affects how these complaints are now processed following the 2023 criminal law reforms. Section 223(1) of the Bharatiya Nagarik Suraksha Sanhita, 2023 introduces a pre-cognizance hearing requirement before a magistrate takes cognizance of certain complaints, and whether this applies to a Section 138 complaint is currently answered differently by different courts. The Karnataka High Court has held that it does not apply, reasoning that the Negotiable Instruments Act is a special statute that displaces the general procedural requirement, relying on the Supreme Court's reasoning in Sanjabij Tari versus Kishore S. Borcar to the same effect. Reported practice in Delhi's trial courts, by contrast, shows magistrates continuing to issue the Section 223 hearing notice in cheque-bounce complaints as a matter of course. Until the Supreme Court resolves this divide, a complainant filing a Section 138 case in Gautam Buddh Nagar should expect the local magistrate's practice to follow whichever position the Allahabad High Court, if it has ruled, or the trial court's own established habit, currently favours, and should not assume the Karnataka position has been adopted uniformly across Uttar Pradesh.

A practical sequence for a lender facing a Noida default

Confirming the correct forum before filing anything saves more time, in this particular geography, than almost any other step a lender can take. Where the loan is secured and the asset qualifies, SARFAESI remains the fastest route to possession, and the demand notice under Section 13(2) should be drafted to record every jurisdictional fact, the asset's location, the borrower's residence and business address, and the branch that sanctioned the loan, so that whichever DRT actually hears a Section 17 challenge, the record already supports jurisdiction there without needing to be reconstructed later.

Where the debt is unsecured, or the security is defective, and the claim exceeds the twenty-lakh-rupee threshold, a Section 19 suit before the DRT is the more direct route than an ordinary civil suit, both for speed and because a Recovery Certificate carries execution powers a civil decree does not automatically have. Where the borrower is a company that shows genuine signs of insolvency rather than mere reluctance to pay, a Section 7 petition before NCLT Allahabad should be considered early rather than as a last resort, since the moratorium that follows admission freezes competing recovery action, including any pending SARFAESI or DRT proceeding, and a creditor who waits until other recovery routes have failed may find the company's assets have deteriorated in the meantime. Throughout, a parallel cheque-dishonour complaint under Section 138, filed promptly after the cheque is returned unpaid and within the statutory notice period the Act requires, adds criminal pressure that frequently accelerates settlement even where the civil or insolvency route is also being pursued, provided the complaint is filed at the correct branch-linked forum from the outset.

A borrower on the receiving end of any of these routes benefits from the same discipline in reverse. Checking whether the DRT, the NCLT or the magistrate's court that has issued process actually holds jurisdiction is not a delaying tactic when the objection is genuine, and the Allahabad High Court's own willingness to intervene where an authority or tribunal has exceeded its notified territory means a properly raised jurisdictional objection can succeed on its own merits. What does not work, on the pattern the case law in this piece shows consistently, is raising jurisdiction as a bare technical objection while ignoring the substance of a default that is otherwise established, since both the DRT and the NCLT have shown little patience for objections used purely to buy time.

Limitation across the four routes

A Section 13(2) demand notice can be issued once the loan account is classified as a non-performing asset under the applicable Reserve Bank of India directions, and the borrower has sixty days to respond before possession measures under Section 13(4) can follow; a Section 17 challenge to those measures must be filed within forty-five days of the measures being taken. A Section 19 suit before the DRT is governed by the general three-year limitation period under the Limitation Act, 1963 for a suit on a debt, running from the date of default or the last acknowledgment of liability, whichever is later, and an appeal from a DRT order to the DRAT must be filed within thirty days under Section 20 of the 1993 Act.

A Section 138 complaint must be filed within one month of the cause of action arising, which is the expiry of the fifteen-day period given to the drawer to make payment after receiving the statutory demand notice following the cheque's return, itself required to be sent within thirty days of the bank's dishonour memo; a magistrate has discretion to condone delay in filing beyond that month for sufficient cause, but the sequence of these three short windows, thirty days to issue notice, fifteen days to await payment, and one month to file thereafter, is unforgiving and has defeated more complaints on technical grounds than any contest on the cheque's validity. A Section 7, 9 or 10 petition before the NCLT carries no separate limitation period under the Code itself, but the underlying debt must not itself be time-barred under the Limitation Act, a point the Supreme Court has enforced strictly in determining whether an application is maintainable at the admission stage.

What remains unsettled

The precise DRT allocated to Gautam Buddh Nagar for Section 17 and Section 19 filings is the most consequential open question in this piece, and it could not be confirmed from the sources available during this research. The pattern of other district allocations makes DRT Allahabad the more probable forum, but a lender or borrower should treat this as a working assumption to be verified against the current gazette notification before filing, not as settled law.

The current operative status of the October 2022 pecuniary-jurisdiction notification concentrating high-value DRT matters at Delhi, Chennai and Mumbai, following the Bombay High Court's stay, is equally unconfirmed, and any claim against a Noida borrower above the one-hundred-crore threshold should be checked against the latest position before a forum is chosen.

Whether the BNSS Section 223(1) pre-cognizance hearing applies to Section 138 complaints remains divided between High Courts and, on the reports available, still pending final resolution before the Supreme Court, which means the procedural shape of a fresh cheque-dishonour complaint filed today in Gautam Buddh Nagar may differ from one filed in a jurisdiction that has already settled the question, and a complainant should expect and plan for that procedural variability rather than assume uniformity.

Noida's position on the map of Indian debt recovery is a genuine anomaly: a district functionally part of the National Capital Region's business economy, but governed, for every tribunal discussed here, by Uttar Pradesh's own forum structure rather than Delhi's. That gap between economic geography and jurisdictional geography is where most of the avoidable delay in this area actually originates, not in the substantive law, which is reasonably settled on SARFAESI procedure, cheque jurisdiction and the insolvency framework, but in assumptions about forum that the facts on the ground do not support.

A lender or borrower who confirms, before filing anything, which DRT actually has jurisdiction, which NCLT bench the registered office dictates, and which court the payee's bank branch fixes for a cheque complaint, starts the recovery or defence process without the self-inflicted delay that a wrong forum causes. The points flagged here as unsettled, principally the exact DRT allocation for Gautam Buddh Nagar and the BNSS pre-cognizance question, are worth tracking directly rather than assuming either answer, since both could move the practical timeline for a Noida recovery matter by months.

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 26 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, 14, 17, 18 and 34
2. Recovery of Debts and Bankruptcy Act, 1993, Sections 3, 19 and 20
3. Insolvency and Bankruptcy Code, 2016, Sections 7, 9, 10 and 14, and Part III
4. Negotiable Instruments Act, 1881, Section 142(2), as inserted by the Negotiable Instruments (Amendment) Act, 2015, with effect from 26 December 2015
5. Bharatiya Nagarik Suraksha Sanhita, 2023, Section 223(1)
6. Commercial Courts Act, 2015, Section 12A
7. Ram Pal Soni v. State of U.P., Allahabad High Court, 2024, on DRT jurisdiction under Section 17 of the SARFAESI Act
8. Dashrath Rupsingh Rathod v. State of Maharashtra, Supreme Court of India, 2014, on drawee-bank jurisdiction under Section 138, prior to the 2015 amendment
9. Supreme Court of India judgment dated 28 November 2025 on account-payee cheque jurisdiction and the payee's home branch rule
10. Sanjabij Tari v. Kishore S. Borcar, Supreme Court of India, cited for the special-law-prevails principle applied to Section 138 complaints
11. Kamlesh Rani Singla and Praveen Kumar Garg, NCLAT, on the requirement that a personal guarantor's insolvency application be filed at the NCLT bench seized of the corporate debtor's CIRP
12. Kerala High Court, IFCI v. Hotel Mythri matter, 2026 (OP(C) No. 2569 of 2026), on res judicata barring a civil suit after an adverse DRT SARFAESI finding
13. NCLT jurisdiction table, nclt.gov.in, listing the Allahabad Bench's territorial jurisdiction over Uttar Pradesh and Uttarakhand
14. Gazette Notification S.O. 345(E) dated 3 February 2017, transferring Haryana's NCLT jurisdiction to the Chandigarh Bench
15. Ministry of Finance notifications S.O. 4717(E), 4718(E) and 4719(E) dated 4 October 2022, on DRT pecuniary jurisdiction reallocation, and the Bombay High Court (Aurangabad Bench) order staying that reallocation
16. Allahabad High Court order in Yadunandan Pandey v. State of U.P. and 3 others, on vacancies affecting the Debts Recovery Tribunal and Appellate Tribunal at Prayagraj
17. Kotak Mahindra Bank Ltd v. Trupti Sanjay Mehta & Ors., 2026 INSC 943, Supreme Court of India, on SARFAESI enforcement over debt assigned from an NBFC not itself covered by the Act
18. Supreme Court of India ruling on SARFAESI auction finality and a borrower's right of redemption pending full payment of the auction consideration
19. Punjab and Haryana High Court order staying dispossession from a sole residential house in a SARFAESI recovery for a debt below twenty lakh rupees

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