Ugro Capital Limited vs The State Of Rajasthan on 20 July, 2026

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    Rajasthan High Court – Jaipur

    Ugro Capital Limited vs The State Of Rajasthan on 20 July, 2026

    [2026:RJ-JP:27861]
    
            HIGH COURT OF JUDICATURE FOR RAJASTHAN
                           BENCH AT JAIPUR
                  S.B. Civil Writ Petition No. 9587/2026
                        URN: CW / 21444U / 2026
    UGRO Capital Limited, A Non-Banking Finance Company (NBFC)
    Registered Under The Companies Act And The Reserve Bank Of
    India Act Having Its Registered Office At Equinox Business Park,
    Tower 3 4Th Floor Lbs Road, Kurla (West), Mumbai -400070,
    CIN: L67120Mh1993Plc070739 Through Its Authorised Officer
    Authorised Signatory (Sujoy Roy), Having Office At District
    Jhalawar, Rajasthan.
                                                                           ----Petitioner
                                        Versus
    1.       The State Of Rajasthan, Through Its Principal Secretary,
             Home Department, Government Secretariat, Jaipur.
    2.       The District Collector-Cum-District Magistrate, District
             Jhalawar, Rajasthan.
    3.       The Superintendent             Of      Police,          District   Jhalawar,
             Rajasthan.
    4.       The Station House Officer, Police Station Bhawanimandi,
             District Jhalawar, Rajasthan
    5.       M/s Kamal Enterprises, A Proprietorship Concern, Having
             Its Office At Khandaar Walon Ka Mohalla, Main Road,
             Karawan, Police Station Bhawanimandi, District Jhalawar
             326512 (Rajasthan), Through Its Proprietor Shri Gopal
             Singh
                                                                        ----Respondents
    For Petitioner(s)          :    Ms. Ayushi with
                                    Mr. Vaibhav &
                                    Mr. Yogesh on behalf of
                                    Mr. Prerit Goyal
    For Respondent(s)          :    Ms. Devakriti Vashishtha with
                                    Ms. Sunita Meena, AGC on behalf of
                                    Mr. Bhuwnesh Sharma, AAG
    
    
    
            HON'BLE MR. JUSTICE ANAND SHARMA
                          Order
    20/07/2026
    
    

    1. Ms. Devakriti Vashishtha, learned counsel, appeared for

    Mr. Bhuwnesh Sharma, learned Additional Advocate General and

    SPONSORED

    accepts notices on behalf of respondent Nos.1 to 4.

    2. Learned counsel for the petitioner submits that the

    private-respondents availed loan facility from the petitioner

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    financial institution however when he failed to repay the same

    proceedings under the provisions of Securitisation and

    Reconstruction of Financial Assets and Enforcement of Security

    Interest Act, 2002 (for short, ‘the Act of 2002’) were initiated and

    after carrying out proceedings under Section 14(2) of the Act of

    2002, an application under Section 14 of the Act of 2002 was

    moved before the concerned District Magistrate, Jaipur.

    3. Learned counsel for the petitioner further submits that

    the application under Section 14 of the Act of 2002 filed by the

    petitioner was allowed by the District Magistrate vide order dated

    25.09.2025 granting directions to the police authorities to provide

    police assistance. Learned counsel also submits that by aid of

    police, physical possession of the secured assets was taken by the

    petitioner on 22.01.2026. After taking possession, in view of

    Section 14 of the Act of 2002, the petitioner had legitimate right

    to continue the possession, yet in quite malicious and

    unauthorized manner, the private respondents re-entered in the

    secured premises by forcibly breaking lock.

    4. This Court finds that the similar controversy arose

    before this Court where after passing the order under Section 14

    of the Act of 2002 and after taking possession thereunder by the

    secured creditor, the borrower re-entered in the secured premises,

    this Court held that the concerned Magistrate does not become

    functus officio and cannot be rendered powerless to issue

    appropriate directions under Section 14(2) of the Act of 2002. In

    the case of Jana Small Finance Bank Limited Vs. State of

    Rajasthan & Ors. (S.B. Civil Writ Petition No. 10026/2026),

    this Court has held as under:

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    “11. Core questions involved in these matters is
    that once the District Magistrate/Chief Metropolitan
    Magistrate issues directions under Section 14 of the Act
    of 2002 directing for taking physical possession of the
    secured asset with the police assistance and pursuant
    thereto, possession is also handed over to the secured
    creditor, a writ petition under Article 226 of the
    Constitution of India would be maintainable or not, in
    the event the borrower forcibly re-enters the secured
    asset in violation of such order, or whether an
    alternative remedy is available under the provisions of
    the Act of 2002.

    12. Since, the controversy revolves around the
    provisions of Section 14(1) and (2), relevant portion
    thereof is being reproduced hereunder:-

    “14. Chief Metropolitan Magistrate or District
    Magistrate to assist secured creditor in
    taking possession of secured asset.–(1)
    Where the possession of any secured assets is
    required to be taken by the secured creditor or if
    any of the secured assets is required to be sold or
    transferred by the secured creditor under the
    provisions of this Act, the secured creditor may,
    for the purpose of taking possession or control of
    any such secured assets, request, in writing, the
    Chief Metropolitan Magistrate or the District
    Magistrate within whose jurisdiction any such
    secured asset or other documents relating thereto
    may be situated or found, to take possession
    thereof, and the Chief Metropolitan Magistrate or,
    as the case may be, the District Magistrate shall,
    on such request being made to him–

    (a) take possession of such asset and documents
    relating thereto; and

    (b) forward such asset and documents to the
    secured creditor:

    1

    [Provided that any application by the secured
    creditor shall be accompanied by an affidavit duly
    affirmed by the authorised officer of the secured
    creditor, declaring that–

    (i) the aggregate amount of financial assistance
    granted and the total claim of the Bank as on the
    date of filing the application;

    (ii) the borrower has created security interest
    over various properties and that the Bank or
    Financial Institution is holding a valid and
    subsisting security interest over such properties
    and the claim of the Bank or Financial Institution
    is within the limitation period;

    (iii) the borrower has created security interest
    over various properties giving the details of
    properties referred to in sub-clause (ii) above;

    (iv) the borrower has committed default in
    repayment of the financial assistance granted
    aggregating the specified amount;

    (v) consequent upon such default in repayment
    of the financial assistance the account of the
    borrower has been classified as a non-performing
    asset;

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    (vi) affirming that the period of sixty days notice
    as required by the provisions of sub-section (2) of
    section 13, demanding payment of the defaulted
    financial assistance has been served on the
    borrower;

    (vii) the objection or representation in reply to the
    notice received from the borrower has been
    considered by the secured creditor and reasons for
    non-acceptance of such objection or
    representation had been communicated to the
    borrower;

    (viii) the borrower has not made any repayment
    of the financial assistance in spite of the above
    notice and the Authorised Officer is, therefore,
    entitled to take possession of the secured assets
    under the provisions of sub-section (4) of section
    13
    read with section 14 of the principal Act;

    (ix) that the provisions of this Act and the rules
    made thereunder had been complied with:

    Provided further that on receipt of the affidavit
    from the Authorised Officer, the District Magistrate
    or the Chief Metropolitan Magistrate, as the case
    may be, shall after satisfying the contents of the
    affidavit pass suitable orders for the purpose of
    taking possession of the secured assets1 [within a
    period of thirty days from the date of application]:

    1

    [Provided 2[also] that if no order is passed by the
    Chief Metropolitan Magistrate or District
    Magistrate within the said period of thirty days for
    reasons beyond his control, he may, after
    recording reasons in writing for the same, pass
    the order within such further period but not
    exceeding in aggregate sixty days.]

    Provided also that the requirement of filing
    affidavit stated in the first proviso shall not apply
    to proceeding pending before any District
    Magistrate or the Chief Metropolitan Magistrate, as
    the case may be, on the date of commencement
    of this Act.]

    3
    [(1A) The District Magistrate or the Chief
    Metropolitan Magistrate may authorise any officer
    subordinate to him,–

    (i) to take possession of such assets and
    documents relating thereto; and

    (ii) to forward such assets and documents to the
    secured creditor.]
    (2) For the purpose of securing compliance with
    the provisions of sub-section (1), the Chief
    Metropolitan Magistrate or the District Magistrate
    may take or cause to be taken such steps and
    use, or cause to be used, such force, as may, in
    his opinion, be necessary.”

    13. Bare perusal of the aforesaid provisions
    would make it clear that under Section 14(1)
    necessary orders can be passed by the Chief
    Metropolitan Magistrate or District Magistrate, as the
    case may be for the purpose of taking possession of the
    secured asset. Section 14(2) of the Act further provides

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    that for the purpose of securing compliance with the
    provisions of sub-section (1) the Chief Metropolitan
    Magistrate or District Magistrate may direct for taking
    necessary steps or cause to be used force which in his
    opinion is necessary.

    14. The expression “for the purpose of
    securing compliance with the provisions of sub-section
    (1)” is apparently having wide amplitude and cannot be
    interpreted in a narrow manner. Once possession is
    handed over under the orders of concerned Magistrate
    under Section 14, it would essentially mean the right of
    secured creditor to continue such possession which is
    an integral part of proceedings under Section 14.
    Section 14(2) of the Act of 2002 would also make it
    clear that such provision confers enabling power upon
    the concerned Magistrate for ensuring compliance of
    any order passed by the Magistrate under Section 14.
    If possession delivered under the Magistrate’s authority
    is subsequently disturbed by force or trespass, the
    Magistrate’s power under Section 14(2) can reasonably
    be construed as extending to restoration of status quo
    ante, so that the original order is not frustrated.

    15. This Court finds that after passing order
    under Section 14 for taking over possession of the
    secured asset and handing over the same to the
    secured creditor, concerned Magistrate does not
    become functus officio and the apprehension of the
    petitioner that after passing initial order under Section
    14
    of the Act of 2002, concerned Magistrate is rendered
    powerless, is totally misconceived and is
    misinterpretation of clear language of Section 14(2) of
    the Act of 2002. In view of the language of the
    aforesaid provision, it is clear that the concerned
    Magistrate is having power not only to take possession
    through police assistance of the secured asset, but
    power is also vested with him for passing subsequent
    orders for ensuring the compliance of earlier order
    passed by the Magistrate. Any other interpretation of
    the aforesaid provision is likely to frustrate the
    proceedings under Section 14 and to render the powers
    conferred to the concerned Magistrate as meaningless
    and ineffective.

    16. Under these circumstances, this Court is of
    the opinion that ensuring compliance of the order
    earlier passed under Section 14 is also integral and
    indispensable part of powers conferred to the
    Magistrate under Section 14(2) of the Act of 2002, in
    case, the borrower or any other person violates the
    directions given by the concerned Magistrate under
    Section 14 and unauthorizedly re-enters in the
    premises of secured asset then the aggrieved secured
    creditor is well within its right to approach the
    concerned Magistrate by way of filing an application
    under Section 14(2) of the Act of 2002 with a prayer to
    secure compliance of earlier order passed by the
    Magistrate. Such application shall be examined in
    accordance with law by the concerned Magistrate and
    appropriate orders for securing compliance of the
    earlier order can be passed. Thus this Court, on the
    basis of foregoing discussion, comes to the conclusion
    that the petitioners are having efficacious remedy
    under the provisions of Section 14(2) of the Act of
    2002 before the concerned Magistrate.

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    17. In the instant cases, admittedly the
    petitioners have not approached the concerned
    Magistrate by way of filing any such application under
    Section 14 (2) of the Act of 2002. This Court finds that
    under such circumstances, the present writ petitions
    filed by the petitioners are totally premature and not
    maintainable. In view foregoing discussions, the writ
    petitions filed by the petitioner can not be entertained
    and are hereby dismissed.

    18. However, mere dismissal of the present
    writ petitions shall not curtail rights of the petitioner
    financial institution to approach the concerned
    Magistrate by way of filing an application under Section
    14(2)
    for securing compliance of earlier order passed
    by the Magistrate under Section 14. Any such
    proceedings shall be treated in continuation to the
    earlier proceedings under Section 14 of the Act of
    2002. The concerned Magistrate, upon filing of such
    application, shall examine the contents of the
    application and shall pass appropriate orders strictly in
    accordance with law, for securing compliance of its
    earlier order passed by the concerned Magistrate for
    the purpose of taking possession of the secured asset
    and to hand over such possession to the secured
    creditor. In the event, any such application is filed,
    same shall be decided expeditiously by the concerned
    Magistrate.”

    5. In view of above judgment, this Court finds that the

    controversy involved in the instant case is squarely covered by the

    judgment dated 30.06.2026 passed in the case of Jana Small

    Finance Bank Limited (supra). Petitioner has not exhausted the

    remedy available under Section 14 of the Act of 2002, thus this

    Court finds that under such circumstances, the present writ

    petition filed by the petitioner is totally premature and not

    maintainable.

    6. In view of above, the instant writ petition is hereby

    dismissed in the same terms and with the same directions and

    liberty granted in Jana Small Finance Bank Limited (supra).

    7. Pending application(s), if any, stand(s), disposed of.

    (ANAND SHARMA),J

    70/DAKSH

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