BANKING & FINANCE

SARFAESI ACT:BORROWER RIGHTS & REMEDIES

Advocate Iranpreet Singh
December 25, 2023
9 min read

The Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest (SARFAESI) Act empowers banks to recover dues without court intervention. However, borrowers have significant rights and legal remedies that must be understood and exercised properly to protect their interests.

UNDERSTANDING SARFAESI ACT

WHAT IS THE SARFAESI ACT?

The SARFAESI Act, 2002, enables banks and financial institutions to recover their non-performing assets (NPAs) without court intervention by taking possession of securities, selling them, and recovering dues. The Act applies to secured debts of ₹1 lakh and above.

KEY FEATURES OF SARFAESI ACT

No Court Intervention Required

Banks can enforce security without approaching courts

Asset Classification

Applies to accounts classified as NPA for 60 days or more

Minimum Threshold

Outstanding amount should be ₹1 lakh or above

Secured Assets Only

Only applies to loans secured by tangible assets

FUNDAMENTAL BORROWER RIGHTS

YOUR RIGHTS UNDER SARFAESI ACT

RIGHT TO RECEIVE PROPER NOTICE

  • 60-day notice before taking possession of secured assets
  • Notice must contain complete details of outstanding dues
  • Opportunity to pay dues and avoid enforcement action
  • Notice must be served at registered address and property location

RIGHT TO REPRESENTATION

  • Right to make representation against proposed action
  • Bank must consider representation before taking action
  • Right to provide additional security or payment plan
  • Right to legal representation during proceedings

RIGHT TO FAIR VALUATION

  • Assets must be valued by qualified valuers
  • Right to challenge valuation if unreasonable
  • Sale should be at fair market value
  • Right to surplus amount after debt recovery
ASSET ENFORCEMENT PROCESS

STEP-BY-STEP ENFORCEMENT PROCEDURE

STAGE 1: DEMAND NOTICE

1Bank issues demand notice for outstanding dues
2Notice period: 60 days to pay or provide security
3Borrower can make representation or payment

STAGE 2: POSSESSION NOTICE

1Bank takes symbolic/physical possession of assets
2Possession notice displayed at property
3Borrower retains right to redeem property

STAGE 3: SALE PROCESS

130-day notice before sale publication
2Public auction or private treaty sale
3Surplus amount returned to borrower
DRT APPEALS PROCESS

DEBT RECOVERY TRIBUNAL APPEALS

FILING DRT APPLICATION

  • Application must be filed within 45 days of SARFAESI action
  • Deposit 50% of claimed amount or ₹25 lakhs (whichever is less)
  • Detailed grounds for challenging bank's action
  • Supporting documents and evidence
  • Prayer for interim relief if required

DRT POWERS AND REMEDIES

Interim Orders

Stay proceedings, protect assets

Final Relief

Set aside action, modify terms

Compensation

Damages for wrongful action

Restructuring

Modified payment terms

IMPORTANT TIMELINE

CRITICAL TIME LIMITS

The 45-day period to file DRT application is strictly enforced. Delay beyond this period can result in dismissal of the application, making it crucial to act promptly upon receiving SARFAESI notice.

PROTECTION AGAINST WRONGFUL ACTION

SAFEGUARDS FOR BORROWERS

  • Banks cannot use force or criminal intimidation
  • Residential premises occupied by borrower cannot be taken
  • Essential household items are protected from seizure
  • Right to approach police for protection against illegal action
  • Banks must follow due process and cannot bypass legal procedures
  • Right to fair and transparent sale process
PRACTICAL GUIDANCE FOR BORROWERS

BEST PRACTICES & RECOMMENDATIONS

IMMEDIATE STEPS UPON RECEIVING NOTICE

  • Verify the authenticity and accuracy of the notice
  • Check calculation of outstanding amount and interest
  • Gather all loan documents and payment records
  • Consult with qualified legal counsel immediately
  • Explore settlement or restructuring options

DOCUMENTATION STRATEGY

Essential Documents

  • Original loan agreement and security documents
  • Payment receipts and bank statements
  • Correspondence with bank
  • Property valuation reports

Evidence Collection

  • Proof of procedural violations
  • Evidence of disputed liability
  • Documentation of hardship circumstances
  • Alternative security or payment proposals

RECENT JUDICIAL DEVELOPMENTS

Recent Supreme Court and High Court judgments have strengthened borrower protections:

  • Strict compliance with notice requirements mandated
  • Banks cannot bypass statutory procedures
  • Borrower's right to fair hearing emphasized
  • Protection against arbitrary and malafide actions
  • Enhanced scrutiny of valuation and sale processes

WHEN TO SEEK LEGAL ASSISTANCE

Professional legal assistance is crucial when:

  • Receiving SARFAESI notice for the first time
  • Disputing the liability or amount claimed
  • Bank has violated procedural requirements
  • Need to file DRT application or appeal
  • Facing possession or sale proceedings
  • Exploring settlement or restructuring options
EXPERT SARFAESI LEGAL DEFENSE

FACING SARFAESI ACTION? GET EXPERT LEGAL HELP

Don't let banks take advantage of procedural lapses or wrongful enforcement. Our experienced team specializes in SARFAESI defense, DRT appeals, and protecting borrower rights under banking laws.