IN THE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CIVIL) NO.

OF 2014

IN THE MATTER OF:

NARENDER KUMAR ARORA

PETITIONER
VERSUS

KOTAK MAHINDRA BANK LTD. & ORS

RESPONDENTS

WRIT PETITION UNDER ART 226 OF THE INDIAN CONSTITUTION

SEEKING ISSUANCE OF WRIT OF CERTIORARI OR MANDAMUS OR
ANY OTHER APPROPRIATE WRIT OR DIRECTION, QUASHING AND
SETTING ASIDE THE ASSIGNMENT DEED DATED 31.10.2012 QUA
THE PORTION WHEREIN THE ACCOUNTS OF THE PETITIONER HAS
BEEN TRANSFERRED, EXECUTED BETWEEN THE RESPONDENT
NO.1 & 2, BEING AGAINST THE GUIDELINES AS WERE LAID
DOWN/PREVALENT THEN BY THE RESPONDENT NO.3.
MOST RESPECTFULLY SHOWETH:
1. That the respondent No.1 approved two home loans in favour of the
petitioner bearing loan references number 14511110 and 14511038 for
an amount of Rs.1,48,00,000/- & Rs.52,00,000/- respectively vide
sanction letter dated 23rd February 2008.

2. That the said loans had to be repaid by way of 180 installments of

Rs.1,72,892/- and 60,746/- respectively and further attracted an
interest of 11.50% P.A.

3. That, however vide letter dated the respondent No.1 granted a

forbearance period of twelve months and the rate of interest was also
reduced to 6.5% P.A. That accordingly the EMIs were reduced to
Rs.1,07,106/- and 37,262 respectively.

4. That further the respondent No.1 issued a letter dated 14.01.2011 to

the petitioner, stating that the installments were being paid regularly
and the status of the account was regular.

5. That, however the respondent No.1 all of a sudden increased the rate
of interest again and the installments of the petitioner were modified to
Rs.1,66,927/- & 58,650/- again.

6. That on 30.03.2010 the respondent No.1 gave a proposal for the early
closure of the loans as obtained. That the petitioner agreeing to the
said proposal deposited Rs.40,00,000/- towards the said proposal.
That, however the respondent No.1 pursuant to accepting the said
amount refused to adhere to the proposal/settlement terms and
declared the said settlement as null and void vide letter dated
29.07.2010.

7. That the respondent No.1 further sent a notice under section 138 of the
Negotiable Instruments Act on the basis of the cheques as given by the
petitioner at the time of sanctioning the loan, and further filed a criminal
complaint against the petitioner which was eventually withdrawn later.

8. The petitioner aggrieved by the illegal retention of the 40,00,000/rupees by the respondent No.1 filed a suit for rendition of accounts
which was disposed off by the Ld.Civil Judge, Saket Court allowing the
parties to take recourse to arbitration.

9. That, however the respondent No.1 bank instead of taking the recourse
as suggested, terminated the loan agreement vide a legal notice dated
27.04.2012. The respondent No.1 further recalled the entire loan.

10. That further vide letter dated 07.05.2012, the respondent No.1
informed the petitioner that as per the arbitration clause in the Loan
agreement, Sh.Rajiv Shukla (Advocate) has been appointed as the
arbitrator for adjudicating disputed between the petitioner and the
respondent No.1.

11. That the petitioner filed an application under the Arbitration and
Conciliation Act before this Honble court, praying the appointment of a
substituted arbitrator, however this Honble court disposed the said
petition vide order dated 28.09.2012 giving a direction to the petitioner
to take appropriate remedies as available to him under law before the
arbitrator.

12. That during the arbitration proceedings the respondent No.1 informed
the arbitrator as well as the petitioner on 17.01.2013 that the loan
account of the petitioner has been assigned to the respondent No.2,
however no documents were produced in this regard.

13. That by virtue of the said assignment deed, the petitioner received
legal notices from the respondent No.2 requesting payment, which
were replied to.

14. That, however on 06.05.2014 the respondent No.2 before the Ld.
Arbitrator filed an application under order 22, rule 10 requesting
substitution in place of respondent No.1. That alongwith the said
application a copy of the assignment deed dated 31.10.2012 was also
filed, and the petitioner was supplied a copy of both the documents.

15. That as per the assignment deed it was stated that:-

The receivables are classified by the assignor as non-performing

assets as of cut off date (as defined below) in accordance with the RBI
guidelines and such receivables have remained as non performing
assets in the books of the assignor for periods ranging from April 2002
to 30 May 2010,

however with regard to the accounts of the petitioner it is mentioned

that both the said accounts were declared as an NPA on 30-June 2012.
Copy of the assignment deed dated 31.10.2012 is annexed herewith
as Annexure X.

16. That upon the perusal of the deed it was discovered that the account
of the petitioner has been assigned in complete contradiction to the
then issued/prevalent guidelines as issued by the respondent No.3 on
13/07/2005. That as per section 35A of the Banking Regulation Act,
1949 the said guidelines had statutory force and further stated that a
non-performing asset in the books of a bank shall be eligible for sale to
other banks only if it has remained a non-performing asset for at least
two years in the books of the selling bank, however as per the
respondent No.3s admission, the accounts of the petitioner were
declared as an NPA on 30-June-2012 and the deed of assignment was
entered into on 31.10.2012. A copy of the guidelines dated 13/07/2005
is annexed herewith.

17. That further the guidelines as issued by the respondent No.3, were
binding on all banks, Financial Institutions as well as NBFCs and
further were issued as per the power granted to the respondent No.3
vide section 35A of the Banking Regulations Act and hence the
respondent No.1 & 2 were bound to follow the same. That further to
demonstrate the statutory flavor in the said guidelines it is stated that

non-compliance of the same is punishable as per 46 of the Banking

Regulations Act.

18. That, however the said guidelines were modified by the respondent
No.3 vide a circular dated 26.02.2014, by way of which the initial
holding period of an NPA was not a mandate to be observed by the
banks anymore, however the said guidelines were never made
applicable with retrospective effect.

19. That it is very evident that the respondent No.1 & 2 entered into the
impugned deed dated 31.10.2012 qua the account of the petitioner
completely in contradiction to the law/guidelines as laid down by the
respondent No.3 then and hence this writ petition.

GROUNDS
(i).

Because the acts as done/being done by the respondent No.1 &

2, are violative of the fundamental rights of the petitioner
company as secured by the Constitution of India as well as are in
complete violation of the principles of natural justice.

(ii).

Because the acts of the respondents No. 1 & 2 are completely in

contradiction to the guidelines as laid down by the respondent
No.3 which were prevalent at the time of the deed dated
31.10.2012 and hence the said acts being against the law as laid
down deserve to be quashed.

(iv).

Because the guidelines as issued by the respondent No.3 are

crystal clear on the point that an NPA has to held by the selling
bank for a period of two years before it will be eligible for sale
further, however the respondent No.1 & 2 despite the said

knowledge have tried to misrepresent, and have further tried to

by pass the law as laid down by way of stating that the
receivables intended to be assigned have remained NPA for a
period ranging from April 2002 to May 2010, however the
accounts of the petitioner which were classified as an NPA on
30-June 2012 have been transferred/assigned by way of the said
deed dated 31-10-2012.

(v).

Because the respondent No.3 has from time to time issued

guidelines regarding NPAs which allow the borrower to opt for a
one time settlement/apply for rehabilitation/regularization and
hence the period of two years for holding the NPA has been
provided for, however the respondent No.1 in complete
contradiction of the guidelines as laid down has assigned the
NPA to the respondent No.2 merely within a span of three
months from the declaration of the said NPA who will only focus
on the recovery of immediate money, rather than allowing the
petitioner to be considered for other avenues as provided under
law.

(vi).

Because the respondent No.3 as per the provisions of the

Banking Regulation Act is supposed to keep a check, with regard
to its guidelines issued by it being followed in true letter and
spirit, however in the present case the respondent No.3 has
chosen to turn a blind eye to the present scenario and has not
taken any action at all.

20. That the petitioner craves the leave of this Honble court to add/amend
or alter any of the grounds in support of the writ petition at the time of
arguments.

21. The petitioner is approaching this Honble court since the respondents
are placed within the jurisdiction of this Honble court and the cause of
action has also arisen within the jurisdiction of this Honble court.

22. That the petitioner does not have any other alternate remedy than to
approach this Honble court by way of this writ petition and it is a fit
case for exercise of power under Art 226 & 227 of Indian Constitution.

23. That arbitration proceedings between the petitioner and the respondent
No.1 are pending, however the petitioner has not filed any other similar
writ petition before this Honble court or before any other High Court or
before the Supreme Court of India challenging the impugned acts in
the present petition.

PRAYER
It is hereby respectfully prayed before this Honble court to:

(i).

Issue an appropriate writ quashing the deed dated 31.10.2012

being against the guidelines dated 13.07.2005 issued/sanctioned
by the respondent No.3.

(ii)

any other order that this Honble court deems fit and necessary in
the interest of justice.

PETITIONER
THROUGH

IN THE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CIVIL) NO.

OF 2013

IN THE MATTER OF:

M/S PINTOJI FOODS PVT.LTD

PETITIONER
VERSUS

PUNJAB NATIONAL BANK AND Anr.

RESPONDENTS

LIST OF DATES AND EVENTS

2000-

That the petitioner was primarily involved in manufacturing

pilses/besan and considering its financial security got
associated with the respondent No.1 bank and started to use
the services as provided by the respondent No.1 bank.

16/01/2002- That the respondent No.2 department issued a circular titled

as Rehabilitation of Sick Small Scale Industrial Units, in the
said circular the respondent No.2 department addressed on
issues like viability of units, and rehabilitation of potentially
viable units. The said circular was floated with the clear-cut
intention of providing timely assistance to sick units.

29/04/2002- That the respondent further floated another circular titled as

Providing timely assistance for rehabilitation of small scale
units. The said circular further clarified the intentions of the
respondent No.2 to provide timely assistance to sick units.

2010-

That despite best possible care observed, the stock of raw

material belonging to the petitioner company was washed
away due to heavy rainfall.

30/06/2010- That due to untimely payments, the petitioners account was

declared as a Non Performing Asset by the respondent
No.1 bank. The petitioners unit further came within the
purview of a sick unit.

11/05/2011- That the petitioner company gave a written representation to

the respondent No.1 bank, requesting rehabilitation/revival.

26/05/2011- That the respondent bank filed an O.A under the The
Recovery of Debts Due to Banks and Financial Institutions
Act bearing number 128/2011 before the Ld.DRT-III, New
Delhi. That on the same day itself the Ld.Presiding officer of
the DRT-III was pleased to restrain the petitioner company
from disposing off, alienating or creating any third party
interest in the unit of the petitioner company bearing address
F-45, Industrial Area, Secundrabad, Bulandshahar, Uttar
Pradesh.

12/08/2011- That

the

respondent

No.1

bank

acting

upon

the

representation of the petitioner company got a Technical

Feasibility and Economic viability report generated. The said
report declared the petitioner company technically feasible
and economically viable subject to certain conditions.

12/09/2011- That the respondent No.2 floated another circular dated

12/09/2011, the said circular requested the scheduled

commercial banks to put in place there own policy for

restructuring and reviving potentially viable units.

Oct-Nov 2011-

The officials of the petitioner company exhausted all

resources and spent the last penny that the petitioner

company had, on fulfilling the terms & conditions as
mentioned in the TEV dated 12/08/2011. The employees of
the petitioner company visited the branch office of the
respondent No.1 at Tri Nagar and intimated the respondent
No.1 bank that the conditions as mentioned in the TEV dated
12/08/2011 stand fulfilled, the employees of the petitioner
company further requested the respondent No.1 bank to
initiate steps towards reviving the petitioner company.

30/01/2012- That since the respondent No.1 bank took no steps to revive
the petitioner company, the petitioner company was
constrained to write another letter to the respondent No.1
further confirming the fulfillment of the terms & conditions as
mentioned in the TEV dated 12/08/2011.

03/05/2012- That since despite repeated representations, the respondent

neither took any steps to revive the petitioner company nor
replied to any representations made earlier, the petitioner
company

was

further

constrained

to

write

another

representation dated 03/05/2012, addressing it to the head

office of the respondent No.1 bank on this occasion.

19/05/2012- That the officials of the petitioner company were shocked to

receive a letter dated 19/05/2012 from the respondent No1
bank, which stated that a decision to reexamine the case of
the petitioner company has been taken.

July 2012-

The respondent No.1 bank deputed an officer, who

conducted inspection at the unit of the petitioner company,
however the petitioner company was informed that this
exercise is a mere formality as before releasing additional
funds an inspection is conducted as per the rules.

Sept-2012- That the officials of the respondent No.1 bank orally

informed the petitioner company that pursuant to the
inspection done in the month of July 2012 a fresh TEV report
was prepared vide which the unit of the petitioner has been
declared non-feasible/unviable. It is further submitted that
the said act of the respondent is clearly in contradiction with
the rules as laid down by the respondent No.2, as well as in
violation of the principles of natural justice.

28/09/2012- That the petitioner company being aggrieved by the said

rejection gave another representation to the respondent
No.1 bank raising voices against the said arbitrary acts.

01/11/2012- That the respondent No.2 floated another circular titled as

Guidelines for rehabilitation of Sick Micro and Small
Enterprises, vide the said circular the respondent No.2
stated that in case a unit has to be declared unviable, the
same cannot be done without giving the promoters a chance
of being heard.

06/12/2012- That due to the petitioner company being mislead by the

respondent No.1 bank, the petitioner company could not file
the written statement before the Honble DRT-III within time
and the Ld.DRT-III was pleased to close the right to file a

written statement on 20/04/2012, however the said right was

revived vide an application decided on 06/12/2012 subject to
deposit of Rs.7, 00,000/- with the respondent No.1 bank.

02/03/2013- That the respondent No.1 bank proceeded under the

SARFAESI Act, and have issued a notice under section
13(4) dated 02/03/2013 of the said act. The respondent No.1
bank has further taken symbolic possession of the unit of the
petitioner company.

Mar-Apr-2013-

That considering the hard work as well as the past

record, the petitioner company has received purchase orders

from Kendriya Bhandar, however due to the respondent No.1
bank not participating in the revival of the petitioner
company, the petitioner company is unable to honor the said
purchase orders.

Hence this petition.

PETITIONER
THROUGH

PRASHANT KATARA, ANUJ SEHRAWAT & SUNIL MUND

ADVOCATES
NEW DELHI
EQUITY LAW CHAMBERS
B-29, 3RD FLOOR
LAJPAT NAGAR-II,
th
DATED 20 APRIL 2013
NEW DELHI-110024
MOBILE: 9818594244

IN THE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CIVIL) NO.

OF 2013

IN THE MATTER OF:

M/S PINTOJI FOODS PVT.LTD

PETITIONER
VERSUS

PUNJAB NATIONAL BANK AND Anr.

RESPONDENTS

APPLICATION UNDER SECTION 151 C.P.C READ WITH RELEVANT

RULES UNDER THE DELHI HIGH COURT RULES, PRAYING BEFORE
THIS HONBLE COURT TO STAY THE PROCEEDING IN O.A
No.128/2011, TITLED AS PUNJAB NATIONAL BANK VS M/S PINTOJI
FOODS AND ORS, PENDING ADJUDICATION BEFORE THE LD. DRTIII, NEW DELHI AND TO FURTHER RESTRAIN THE RESPONDENT
NO.1 BANK TO PROCEED FURTHER UNDER THE SARFAESI ACT,
DURING THE PENDENCY OF THIS PETITION.

MOST RESPECTFULLY SHOWETH:

1.

That the petitioner has filed the present petition under Art 226 & 227
of the constitution, praying before this Honble court to issue an
appropriate direction to the respondent No.1 to take steps to
rehabilitate the petitioner company immediately.

2.

That the respondent No.1 bank in clear cut violations of the

circulars issued by the respondent No.2, has gone all guns blazing
to recover its money, however using ways clearly in contradiction to
the circulars issued by the respondent No.2 annexed herewith.

3.

That upon the request for rehabilitation as submitted by the

petitioner the respondent No.1 bank instead of extending relief and
concessions, filed an O.A bearing number 128/2011, under relevant
provisions of the Recovery of Debts Due to Fianancial Institutions
Act, that the said O.A was listed before the Honble DRT-III on
26/05/2011. That on the same day itself the Ld.Presiding officer,
DRT-III, was pleased to restrain the petitioner company to dispose
off/alienate, or create third party interest in the property bearing
address F-45, Induatrial Area, Secundrabad, Bulandshaher, Uttar
Pradesh.

4.

That pursuant to the above mentioned development the petitioner

company on various occasions represented to the bank praying for
additional loan as per the guidelines formulated by the respondent
No.2, however the respondent No.1 bank kept delaying the said
procedure.

5.

That, the respondent No.1 bank finally on 12/08/2011 deputed a

official and got the technical feasibility and economic viability report
generated, the said report declared the unit of the petitioner
Viable, however subject to certain terms & conditions.

6.

That the petitioner company exhausted all its resources, and spent
the last penny it had on fulfilling the said terms & conditions, the
said fulfillment was intimated to the respondent No.1 bank on finally
on 30/09/2011, 30/01/2012 and finally on 30/05/2012.

7.

That the respondent No.1 bank, in clear cut violation of the

principles of natural justice and the guidelines as laid down by the
respondent No.2, wrote a letter to the petitioner company dated

19/05/2012 and informed that a decision has been taken to

reexamine the case of the petitioner company.

8.

That, around July 2012 an officer was deputed by the respondent

No.1 bank for the said purpose. That the said officer inspected the
unit of the petitioner company, however upon asking the said officer
informed the officials of the petitioner company that the present
inspection was a mere formality before releasing additional funds.

9.

That the acts of the respondent No.1 bank reached the heights of
arbitrariness when the officials of the petitioner company were
intimated that pursuant to the fresh inspection another fresh/second
TEV report was formulated and vide the same the unit of the
petitioner company was declared unviable. That it is further
pertinent to mention that the said decision to declare the unit of the
petitioner from Viable to unviable was taken without giving the
officials of the petitioner company a chance to be heard. That
despite repeated requests a copy of the fresh/second TEV has till
date not been provided to the petitioner company.

10.

That the petitioner company through written representations

intimated

the

officials

of

the

respondent

No.1

bank,

his

dissatisfaction against the said rejection, however the respondent

No.1 bank has till date not done anything at all.

11.

That due to the petitioner company being mislead by the

respondent No.1 bank, they could not file the written statement
before the Honble DRT-III within time, and the presiding officer of
the Honble DRT-III, was pleased to close the right of the petitioner
company to file a written statement vide order dated 20/04/2012.

12.

That, however the petitioner company vide an application bearing

number I.A 1047/2012, got the said right revived, however the said
right was revived subject to a deposit of Rs. 7,00,000/- with the
respondent No.1 bank.

13.

That since the petitioner company exhausted the last of its

resources in fulfilling the terms & conditions as mentioned in the
TEV report dated 12/08/2011, the petitioner company have not paid
the said amount till date, and hence the written statement filed by
the petitioner company has not come on record.

14.

That the respondent No.1 bank issued a notice under section 13(4)
of the SARFAESI Act dated 02/03/2013, and have already taken the
symbolic possession of the unit of the petitioner bearing address
F-45, Industrial Area Secundrabad, Bulandshaher, Uttar Pradesh
and hence their amount stands secured.

15.

That the intentions of the respondent No.2 are very clear from the
circulars annexed herewith. The intention of the respondent No.2, is
to provide timely assistance to sick units, and further revive
potentially viable units.

16.

That the acts of the respondent No.1 bank are abundantly contrary
to the intention/guidelines made by the respondent No.2.

17.

That further the acts of the respondent No.1 bank in getting a fresh
TEV report, which is absolutely contrary to the one prepared earlier
is arbitrary, malicious and in clear cut violation to the circulars as
issued by the respondent No.2, as well as in violation of principles
of natural justice.

18.

That the act of the respondent No.1 bank in declaring the petitioner
companys unit from Viable to Unviable without giving the
petitioner an opportunity to be heard is in contradiction of the
cardinal principle of law Audi Alteram Partem.

19.

That in case the proceedings before the Ld.DRT-III, are not stayed
immediately, the Presiding officer has the jurisdiction and authority
to immediately go ahead and issue a recovery certificate against
the petitioner company and in case the said is done the petitioner
will be condemned unheard and the illegal and arbitrary acts done
by the respondent No.1 bank will go unquestioned.

20.

That in case the respondent No.1 bank is not restrained to proceed

further under the Sarfaesi Act, the procedure is such that without
the petitioner company being given any chance to be heard, the
respondent No.1 bank would get an order for taking physical
possession of the unit of the petitioner company and in case the
said is done the petitioner will be condemned unheard and the
illegal and arbitrary acts done by the respondent No.1 bank will go
unquestioned.

21.

That petitioner has a prima facie good case and is likely to succeed.

22.

That in case the relief prayed by way of this application is not

granted at this stage itself, irreparable loss will be borne by the
petitioner.

It is hereby respectfully prayed before this Honble court to

(i).

Issue an interim order/direction staying the proceedings pending in

O.A No.128/2011, pending adjudication before the Ld.DRT-III, New
Delhi during the pendency of this petition.

(ii).

Issue an interim order/direction, restraining the respondent No.1

bank to proceed further under the SARFAESI Act, during the
pendency of this petition.

(ii)

any other order that this Honble court deems fit and necessary in
the interest of justice.

PETITIONER
THROUGH

PRASHANT KATARA, ANUJ SEHRAWAT & SUNIL MUND

ADVOCATES
NEW DELHI
EQUITY LAW CHAMBERS
B-29, 3RD FLOOR
LAJPAT NAGAR-II,
th
DATED 20 APRIL 2013
NEW DELHI-110024
MOBILE: 9818594244

IN THE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CIVIL) NO.

OF 2013

IN THE MATTER OF:

M/S PINTOJI FOODS PVT.LTD

PETITIONER
VERSUS

PUNJAB NATIONAL BANK AND Anr.

RESPONDENTS

MEMO OF PARTIES
M/S PINTOJI FOODS PVT.LTD,
THROUGH ITS DIRECTOR SH.A.N.JHA
R/O D-345/A, GALI NO.19,
BHAJANPURA,
DELHI-110053

.PETITIONER
VERSUS

1.

PUNJAB NATIONAL BANK,

THROUGH THE CHAIRMAN & MANAGING DIRECTOR,
7, BHIKAJI CAMA PLACE,
NEW DELHI.

2.

RESERVE BANK OF INDIA,

THROUGH ITS REGIONAL DIRECTOR FOR DELHI,
6, SANSAD MARG,
P.B.NO.696,
NEW DELHI -110 001.

.RESPONDENTS

PETITIONER
THROUGH

PRASHANT KATARA, ANUJ SEHRAWAT & SUNIL MUND

ADVOCATES
NEW DELHI
EQUITY LAW CHAMBERS
B-29, 3RD FLOOR
LAJPAT NAGAR-II,
th
DATED 20 APRIL 2013
NEW DELHI-110024
MOBILE: 9818594244
IN THE HIGH COURT OF DELHI AT NEW DELHI
WRIT PETITION (CIVIL) NO.

OF 2013

IN THE MATTER OF:

M/S PINTOJI FOODS PVT.LTD

PETITIONER
VERSUS

PUNJAB NATIONAL BANK AND Anr.

RESPONDENTS

INDEX
SL.NO.

PARTICULARS

PAGE NO

1.

LETTER OF SERVICE

2.

URGENT APPLICATION

3.

MEMO OF PARTIES

4.

LIST OF DATES AND EVENTS

5.

WRIT PETITION UNDER ARTICLE 226 & 227

ALONGWITH AFFIDAVIT

6.

ANNEXURE P-1
ORIGINAL BOARD RESOLUTION DATED
19/04/2013.

7.

ANNEXURE P-2
COPY OF CIRCULAR DATED 16/01/2002

8.

ANNEXURE P-3

COPY OF CIRCULAR DATED 29/04/2002

9.

ANNEXURE P-4(COLLY)
COPY OF LETTER DATED 11/05/2011
WITH THE TYPED COPY OF THE
RELEVANT PORTION.

10.

ANNEXURE P-5(COLLY)
COPY OF THE ORDER DATED
26/05/2011 WITH THE TYPED
COPY OF THE RELEVANT PORTION.

11.

ANNEXURE P-6 (COLLY)

COPY OF THE TEV REPORT DATED
12/08/2011 WITH THE TYPED
COPY OF THE RELEVANT PORTION.

12.

ANNEXURE P-7
COPY OF THE CRCULAR DATED 12/09/2011

13.

ANNEXURE P-8 (COLLY)

COPY OF THE LETTER DATED 30/01/2012
WITH PROOF OF SERVICE

14.

ANNEXURE P-9
COPY OF THE LETTER DATED 03/05/2012

15.

ANNEXURE P-10
COPY OF THE LETTER DATED 19/05/2012

16.

ANNEXURE P-11 (COLLY)

COPY OF THE LETTER DATED 28/09/2012

WITH ITS TRUE TYPED COPY

17.

ANNEXURE P-12
COPY OF THE CIRCULAR DATED 1/11/2012

18.

ANNEXURE P-13(COLLY)
COPY OF THE ORDER DATED 06/12/2012
WITH ITS TRUE TYPED COPY

19.

ANNEXURE P-14(COLLLY)
COPY OF THE NOTICE DATED 02/03/2013
WITH ITS TRUE TYPED COPY

20.

ANNEXURE P-15 (COLLY)

COPY OF PURCHASE ORDERS DATED
13/03/2013, 06/04/2013 & 12/04/2013

21.

APPLICATION U/S 151 CPC PRAYING

INTERIM RELIEF WITH SUPPORTING AFFIDAVITS.

22.

APPLICATION U/S 151 CPC PRAYING

EXEMPTION FROM FILING CERTIFIED COPIES.

23.

APPLICATION U/S 151 CPC PRAYING

EXEMPTION FROM FILING TYPED COPIES.

24.

VAKALATNAMA

PETITIONER
THROUGH

PRASHANT KATARA, ANUJ SEHRAWAT & SUNIL MUND

ADVOCATES
NEW DELHI
EQUITY LAW CHAMBERS
B-29, 3RD FLOOR
LAJPAT NAGAR-II,
th
DATED 20 APRIL 2013
NEW DELHI-110024
MOBILE: 9818594244
IN THE HIGH COURT OF DELHI AT NEW DELHI
WRIT PETITION (CIVIL) NO.
OF 2013
IN THE MATTER OF:
M/S PINTOJI FOODS PVT.LTD

PETITIONER
VERSUS

PUNJAB NATIONAL BANK AND Anr.

RESPONDENTS

LETTER OF SERVICE
To,
The Standing Counsel
Punjab National Bank
Sir/Madam,

Please take notice that the petitioner has filed the present
petition in the High Court of Delhi which will be coming up for
hearing on

April, 2013 or any date thereafter as may be

convenient to the Honble court.

You are requested to be present in the court at the time of

hearing.

Yours faithfully,

PETITIONER
THROUGH
PRASHANT KATARA, ANUJ SEHRAWAT & SUNIL MUND
ADVOCATES
NEW DELHI
EQUITY LAW CHAMBERS
B-29, 3RD FLOOR
LAJPAT NAGAR-II,

DATED 20th APRIL 2013

NEW DELHI-110024
MOBILE: 9818594244

IN THE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CIVIL) NO.

OF 2013

IN THE MATTER OF:

M/S PINTOJI FOODS PVT.LTD

PETITIONER
VERSUS

PUNJAB NATIONAL BANK AND Anr.

RESPONDENTS

LETTER OF SERVICE
To,
Rererve Bank of India,
Through its regional director,
New Delhi
Sir/Madam,
Please take notice that the petitioner has filed the present
petition in the High Court of Delhi which will be coming up for
hearing on

April, 2013 or any date thereafter as may be

convenient to the Honble court.

You are requested to be present in the court at the time of

hearing.

Yours faithfully,

PETITIONER
THROUGH
PRASHANT KATARA, ANUJ SEHRAWAT & SUNIL MUND
ADVOCATES
NEW DELHI
EQUITY LAW CHAMBERS
B-29, 3RD FLOOR
LAJPAT NAGAR-II,
DATED 20th APRIL 2013
NEW DELHI-110024

MOBILE: 9818594244

IN THE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CIVIL) NO.

OF 2013

IN THE MATTER OF:

M/S PINTOJI FOODS PVT.LTD

PETITIONER
VERSUS

PUNJAB NATIONAL BANK AND Anr.

RESPONDENTS

URGENT APPLICATION
To,
The Deputy Registrar,
Delhi High Court,
New Delhi.
Sir,
Will you kindly treat this accompanying writ petition as an urgent one
in accordance with the High Court Rules and Orders
The grounds of urgency are
that stay of proceedings before the Debt Recovery Tribunal are
prayed for

Yours faithfully,
PETITIONER
THROUGH
PRASHANT KATARA, ANUJ SEHRAWAT & SUNIL MUND
ADVOCATES
NEW DELHI
EQUITY LAW CHAMBERS
B-29, 3RD FLOOR

LAJPAT NAGAR-II,
NEW DELHI-110024
MOBILE: 9818594244

th

DATED 20 APRIL 2013

IN THE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CIVIL) NO.

OF 2013

IN THE MATTER OF:

M/S PINTOJI FOODS PVT.LTD

PETITIONER
VERSUS

PUNJAB NATIONAL BANK AND Anr.

RESPONDENTS

APPLICATION UNDER SECTION 151 CPC FOR EXEMPTION FROM

FILING CERTIFIED COPIES.

RESPECTFULLY SHOWETH:

1.

That the petitioner has filed the instant writ petition seeking urgent
directions to the respondent.

2.

That due to urgency in filing the writ petition, the petitioner could not
get the certified copies of Annexures P2, P3, P5, P7, P-12 & P-13.

3.

That the petitioner will apply for certified copies, and shall file the
same as and when available.
It is respectfully prayed that filing of certified copies of Annexures
P2, P3, P5, P7, P-12 & P-13 may kindly be exempted.

PETITIONER
THROUGH
PRASHANT KATARA, ANUJ SEHRAWAT & SUNIL MUND
ADVOCATES

NEW DELHI

EQUITY LAW CHAMBERS

B-29, 3RD FLOOR
LAJPAT NAGAR-II,
NEW DELHI-110024
MOBILE: 9818594244

DATED 20th APRIL 2013

IN THE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CIVIL) NO.

OF 2013

IN THE MATTER OF:

M/S PINTOJI FOODS PVT.LTD

PETITIONER
VERSUS

PUNJAB NATIONAL BANK AND Anr.

RESPONDENTS

APPLICATION UNDER SECTION 151 CPC FOR EXEMPTION FROM

FILING TYPED COPIES.

RESPECTFULLY SHOWETH:

1.

That the petitioner has filed the instant writ petition seeking urgent
directions to the respondent.

2.

That due to urgency in filing the writ petition, the petitioner could not
get the copies of Annexures P-15 (colly) typed.

3.

That the petitioner shall get the said typed copies, and shall file the
same as and when available.
It is respectfully prayed that filing of typed copies of Annexures P15 (colly) may kindly be exempted.

PETITIONER
THROUGH
PRASHANT KATARA, ANUJ SEHRAWAT & SUNIL MUND
ADVOCATES

NEW DELHI
DATED 20th APRIL 2013

EQUITY LAW CHAMBERS

B-29, 3RD FLOOR
LAJPAT NAGAR-II,
NEW DELHI-110024
MOBILE: 9818594244