Ummeed Housing Finance Private Limited vs Commissioner Of Police on 20 July, 2026

    0
    7
    ADVERTISEMENT

    Rajasthan High Court – Jaipur

    Ummeed Housing Finance Private Limited vs Commissioner Of Police on 20 July, 2026

    [2026:RJ-JP:27728]
    
            HIGH COURT OF JUDICATURE FOR RAJASTHAN
                        BENCH AT JAIPUR
    
                     S.B. Civil Writ Petition No. 11383/2026
                           URN: CW / 25249U / 2026
    
    Ummeed Housing Finance Private Limited, Reg. Office At Office
    No. 2009-2014, 20Th Floor, Magnum Global Park, Sector 58,
    Gurgaon, Haryana - 122011 Through The Authorized Officer Mr.
    Jai Sharma, Branch Office At 3rd Floor, Axis Mall, Bhagwan Das
    Road, C-Scheme, Jaipur, Rajasthan-302001.
                                                                         ----Petitioner
                                         Versus
    1.       Commissioner of Police, Jaipur, Rajasthan.
    2.       Deputy Commissioner of Police (North) Jaipur, Rajasthan.
    3.       Station House Officer, Police Station-Jaisinghpura Khor,
             District- Jaipur, Rajasthan.
    4.       District Magistrate, Jaipur, Rajasthan.
    5.       Mrs. Radha Devi W/o Shri Satish Singh, Residing At A-24,
             Bajrang Colony, Jaisinghpura Khor, Jaipur, Rajasthan-
             302027
    6.       Mr. Satish Singh S/o Shri Sukhdev Singh, Residing At A-
             24,bajrang Colony, Jaisinghpura Khor, Jaipur, Rajasthan-
             302027
    7.       Mr. Alok Singh Thakur S/o Shri Satish Singh Thakur,
             Residing At 24-A, Bajrang Colony, Jaisinghpura Khor,
             Jaipur, Rajasthan-302027
                                                                      ----Respondents

    For Petitioner(s) : Mr. Akshay Khandelwal for
    Mr. Saransh Ghiya
    For Respondent(s) : Mr. Somitra Chaturvedi, Dy.G.C

    HON’BLE MR. JUSTICE ANAND SHARMA

    SPONSORED

    Order

    20/07/2026

    1. Mr. Somitra Chaturvedi, Dy.G.C. appeared and accepted

    notices on behalf of respondent Nos.1 to 4.

    (Uploaded on 23/07/2026 at 09:44:57 AM)
    (Downloaded on 24/07/2026 at 01:40:22 AM)
    [2026:RJ-JP:27728] (2 of 7) [CW-11383/2026]

    2. Learned counsel for the petitioner submits that the

    private-respondents availed loan facility from the petitioner

    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 (SARFAESI) 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.

    Learned counsel submits that the application under Section 14 of

    the Act of 2002 filed by the petitioner was allowed by the District

    Magistrate granting directions to the police authorities to provide

    police assistance and the rectified on 04.07.2023. Learned counsel

    submits that by aid of police, physical possession of the secured

    assets was taken by the petitioner on 24.12.2025. 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. Feeling aggrieved, the petitioner

    again approached the concerned District Collector by way of filing

    an application with a prayer to direct for restoration of possession.

    However, an application filed by the petitioner has been dismissed

    vide order dated 13.04.2026 by the concerned District Magistrate

    with the findings that after passing the initial final order dated

    04.07.2023, the District Magistrate become functus officio.

    3. This Court finds that the similar controversy arose

    before this Court where after passing the order under Section 14

    (Uploaded on 23/07/2026 at 09:44:57 AM)
    (Downloaded on 24/07/2026 at 01:40:22 AM)
    [2026:RJ-JP:27728] (3 of 7) [CW-11383/2026]

    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. in S.B.

    CWP No. 10026/2026, this Court has held as under:

    “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

    (Uploaded on 23/07/2026 at 09:44:57 AM)
    (Downloaded on 24/07/2026 at 01:40:22 AM)
    [2026:RJ-JP:27728] (4 of 7) [CW-11383/2026]

    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;

    (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,

    (Uploaded on 23/07/2026 at 09:44:57 AM)
    (Downloaded on 24/07/2026 at 01:40:22 AM)
    [2026:RJ-JP:27728] (5 of 7) [CW-11383/2026]

    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 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

    (Uploaded on 23/07/2026 at 09:44:57 AM)
    (Downloaded on 24/07/2026 at 01:40:22 AM)
    [2026:RJ-JP:27728] (6 of 7) [CW-11383/2026]

    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.

    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.”.

    4. In view of above judgment, this Court finds that since

    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), therefore, the order dated

    13.04.2026 passed by District Magistrate/Collector, Jaipur is

    (Uploaded on 23/07/2026 at 09:44:57 AM)
    (Downloaded on 24/07/2026 at 01:40:22 AM)
    [2026:RJ-JP:27728] (7 of 7) [CW-11383/2026]

    hereby quashed and set-aside and the matter is remanded back to

    the District Magistrate Collector for reconsidering the application

    for restoration of possession filed by the petitioner in the light of

    above judgment in the case of Jana Small Finance Bank Ltd.

    (supra) on receiving certified copy of this order, the concerned

    Magistrate shall make an endeavour to decide the application

    expeditiously and preferably within a period of two months from

    the date of receipt of certified copy of this order.

    5. Pending application(s), if any, shall also stand(s),

    disposed of.

    (ANAND SHARMA),J

    43/NEERU

    (Uploaded on 23/07/2026 at 09:44:57 AM)
    (Downloaded on 24/07/2026 at 01:40:22 AM)

    Powered by TCPDF (www.tcpdf.org)



    Source link

    LEAVE A REPLY

    Please enter your comment!
    Please enter your name here