No Right to Proceed Under SARFAESI Act – Even With Possession: Interim Moratorium Shuts the Door Once Personal Insolvency Application is Filed – NCLAT

In a groundbreaking interpretation of the law, the moment an application for Personal Insolvency is filed, the interim moratorium kicks in, bringing SARFAESI proceedings to a screeching halt—even if the possession of the property has already been taken by the creditor!

This ruling underlines the powerful protection that the Insolvency and Bankruptcy Code provides to individuals, locking creditors out from continuing any recovery proceedings under the SARFAESI Act once the insolvency process begins. The filing triggers an immediate freeze, halting all further actions, including the sale or transfer of seized assets.

In short: No more SARFAESI—No more recovery—Not even with possession in hand!

Appellant contented that prior to the proceedings under Section 95 of the Insolvency and Bankruptcy code 2016, the Appellant had filed proceedings under Section 13(4) of the SARFAESI Act, 2002 and had taken symbolic possession of the subject mortgaged property.

Subsequent to that an application under Section 95 of the Insolvency and Bankruptcy code 2016 was filed to initiate insolvency proceedings against the Personal Guarantor. The Ld. NCLT had initiated personal insolvency against the Respondent and held that the moratorium had commenced in relation to all debts of the appellant upon filing of the Company Petition.

It is alleged by the appellant that it had got a vested right in the subject property upon taking its symbolic possession and thus had become a de-facto owner of such property and thus had a vested right to dispose of such mortgaged property to its intending purchaser.

Considering, recent judgement dated 2nd July 2024 by Delhi High Court in Sanjay Dhingra Vs IDBI Bank Ltd & Ors WP(C) No.8131/2020 wherein it was held that the respondent bank cannot proceed further under the SARFAESI Act, in view of the interim moratorium, operating on account of the Insolvency Proceedings pending against the petitioner, the personal guarantor. Further, it was held that, as and when the interim moratorium is lifted, and the respondent bank proceeds under the SARFAESI Act, the petitioner shall be at liberty to approach the learned DRT and raise all issues.

Hon’ble NCLAT directed that the appellant shall not proceed further under the SARFAESI Act qua the subject property till the moratorium is lifted. The appeal thus stands dismissed.: Indiabulls Asset Reconstruction company Ltd. v. Pawan Kapoor, NCLAT New Delhi.

Membership Terms & Conditions

  1. Eligibility Criteria:
    • Membership is open exclusively to Insolvency Professionals (IPs) registered with the Insolvency and Bankruptcy Board of India (IBBI).
    • If your IBBI registration is terminated or surrendered, you must notify IP Net within 7 days. Your IP Net membership will be automatically reviewed and may be subject to termination.
  2. Application Process:
    • By submitting the membership application form, you certify that all information provided is accurate and complete. Any false or misleading information may result in the rejection of your application or termination of your membership.
    • Membership approval is at the sole discretion of IP Net, and we reserve the right to accept or reject any application without providing a reason.
  3. Membership Fees:
    • Membership to IP Net is currently offered free of charge. However, IP Net reserves the right to introduce membership fees in the future, with prior notice given to all members.
    • Any future fees will be clearly communicated, and members will have the option to renew their membership under the new terms.
  4. Use of Information:
    • By becoming a member of IP Net, you agree to the use of your personal and professional information by IP Net and Tranzission for various purposes, including but not limited to communication, newsletters, event invitations, promotional activities, research, and analysis.
    • IP Net and Tranzission may share your information with third-party partners for collaboration purposes, while ensuring compliance with applicable data protection laws.
    • You may request to update or correct your information at any time by contacting IP Net’s support team.
  5. Code of Conduct:
    • Members are expected to uphold the highest standards of professionalism and integrity in all interactions within the IP Net community, including in-person meetings, online forums, and communication channels.
    • Harassment, discrimination, or any form of unethical behavior will not be tolerated and may result in immediate termination of membership.
  6. WhatsApp Group Etiquettes:
    • IP Net provides a WhatsApp group for members to facilitate communication and networking. Members are expected to:
      • Engage in respectful and constructive discussions.
      • Avoid sharing irrelevant or promotional content unless explicitly permitted by the group admin.
      • Refrain from forwarding chain messages, unsolicited invitations, or any form of spam.
      • Report any inappropriate behavior to the group admin.
    • IP Net reserves the right to remove members from the WhatsApp group for non-compliance with these etiquettes.
  7. Use of IP Net Logo:
    • Members are not authorized to use the IP Net logo or branding on their business cards, websites, marketing materials, or any other collateral without prior written permission from IP Net.
    • When permission is granted, the use of the IP Net logo must adhere strictly to the guidelines provided, including size, placement, and context.
    • The IP Net logo cannot be used in any public-facing materials, including webinars, presentations, or publications, unless specifically approved by IP Net in writing.
  8. Confidentiality:
    • As a member of IP Net, you may have access to confidential information, including but not limited to strategic plans, member data, and proprietary research. You agree to keep such information confidential and not to disclose it to any third party without the explicit consent of IP Net.
    • This obligation of confidentiality extends beyond the termination of your membership.
  9. Termination of Membership:
    • IP Net reserves the right to terminate your membership at any time for violations of these terms and conditions, misconduct, or any actions that may harm the reputation or interests of IP Net.
    • You may voluntarily terminate your membership by providing written notice to IP Net. Upon termination, all rights and privileges associated with membership will cease.
  10. Limitation of Liability:
    • IP Net and Tranzission shall not be liable for any direct, indirect, incidental, or consequential damages arising out of or related to your membership, participation in events, or use of any information provided by IP Net.
    • Membership in IP Net does not confer any legal rights or entitlements beyond those expressly stated in these terms and conditions.
  11. Governing Law and Jurisdiction:
    • These terms and conditions are governed by and construed in accordance with the laws of India.
    • Any disputes arising out of or related to your membership in IP Net shall be subject to the exclusive jurisdiction of the courts in New Delhi.
  12. Amendments to Terms and Conditions:
    • IP Net reserves the right to amend or update these terms and conditions at any time. Members will be notified of any significant changes via email or other communication channels.
    • Continued membership following the notification of changes constitutes your acceptance of the amended terms and conditions.
  13. Miscellaneous:
    • These terms and conditions constitute the entire agreement between you and IP Net concerning your membership and supersede any prior agreements or understandings.
    • If any provision of these terms and conditions is found to be invalid or unenforceable, the remaining provisions will continue in full force and effect.

By submitting the membership form, you acknowledge that you have read, understood, and agree to abide by these terms and conditions.