A

PROJECT

ON

“DEBT RECOVERY TRIBUNAL- A CRITICAL STUDY”

SUBJECT: BANKING LAW

CHANAKYA NATIONAL LAW UNIVERSITY, PATNA

SUBMITTED TO: SUBMITTED BY:

DR. B. RAVI NARAYAN SHARMA GAURAV SINHA

ASSISTANT PROFESSOR (LAW) ROLL NO. 112

1ST SEMESTER (LL.M)

ACKNOWLEDGEMENT

I take this opportunity to express my profound gratitude and deep regard to my course in-
charge and guide Dr. B.R.N. Sharma for his exemplary guidance, monitoring and constant
encouragement throughout the course of this project. The help and guidance given by him
from time to time did not only help me in the successful completion of the project but shall
also help me immensely in the journey of life on which I am about to embark.

I am obliged to staff members of Chanakya National Law University, for the valuable
information provided by them in their perspective fields. I am grateful to their cooperation
during the period of my assignment.

Last but not the least, I thank my parents and my friends for their constant support and
encouragement without which this project would not be possible.
CERTIFICATE OF DECLARATION

This is to certify, that the research paper titled “DEBT RECOVERY TRIBUNAL- A
CRITICAL STUDY” is an outcome of my independent and original work to the best of my
knowledge. I have duly acknowledged all the sources from which the ideas and extracts have
been taken. The project has not been submitted elsewhere for publication.
Contents
ACKNOWLEDGEMENT...........................................................................................................................2
CERTIFICATE OF DECLARATION.............................................................................................................3
SYNOPSIS...............................................................................................................................................5
Aim and Objectives................................................................................................................................5
Hypothesis.............................................................................................................................................5
Research methodology..........................................................................................................................5
INTRODUCTION.....................................................................................................................................6
Establishment of the Debt Recovery Tribunal.......................................................................................7
Laws of Debt Recovery Tribunal............................................................................................................9
Constituents of a Debt Recovery Tribunal...........................................................................................11
Judicial decisions.................................................................................................................................14
Conclusion and Suggestions................................................................................................................17
Bibliography.........................................................................................................................................18
SYNOPSIS
Banks and financial institutions had been experiencing considerable difficulties in recovering
loans and enforcement of securities charge with them. The procedure for recovery of debts
due to the banks and financial institutions is very tedious. In the end result there is always
significant portion of funds is blocked.

The Shri M Narasimhan committee on financial systems considered the setting up of the
“special tribunals” with special powers for adjudication and speedy recovery of such matters.
The functioning of DRTs needs to improve to ensure banks are able to recover their existing
loans and offer fresh advances at cheaper rates... In the current scheme of things, there is no
mechanism in place to ensure that the tribunal disposes the case in a timely manner. There is
a strong need to bring in more accountability for the DRT. The biggest challenge, it appears,
is their ability to deal with a subject with speed.

Aim and Objectives

The main objective of the Debt recovery Act, 1991 is to dispose the claims of banks fast.
However it is not the condition in present scenario. The aim of this paper is to critically
analyse the Debt recovery Act, 1991.

Hypothesis
The Debt Recovery Tribunal is working inefficiently because there are a lot of cases pending
before the tribunals. Judicial delay is the major hurdle for the failure of Debt recovery
Tribunal.

Research methodology

The research methodology used by the researcher is doctrinal

INTRODUCTION
Banks and money related organizations had been encountering extensive troubles in
recuperating credits, and implementation of securities accuse of them. The system for the
recuperation of obligations because of the banks and money related establishments was
moderate and brought about a huge part of the assets being seized. Keeping in line with the
international trends on helping financial institutions, recovering their bad debt quickly and
efficiently, the Government of India has constituted thirty-three Debt Recovery Tribunals
(hereinafter referred to as the ‘DRT’) and five Debt Recovery Appellate Tribunals
(hereinafter referred to as the ‘DRAT’) across the country. The banking system has evolved
since then. We have well-established banks now in the 21st century huge ones having more
than $1 trillion in assets. The banking (or credit) sector is one that hold the reins of the world
economy. Without the presence of a well-established credit-system, we cannot expect the
economy to roll on. A dynamic banking system is essential for a thriving economy. Banking
in India faces the difficulty of mounting Non Performing Assets (hereinafter referred to as
‘NPA’), which is unfavourable for the bank’s financial health. Banks have had to wait for
very long time in Civil Courts to get cases concerning debt-recovery disposed and recovered.
This led to the trapping of crores of rupees in litigation proceedings, which the bank could
not re-advance, forcing the Government to establish a Debt Recovery Tribunals to assure
expeditious recovery proceedings and speedy adjudication of matters concerning debt
recovery of banks.

In 1981, Shri T Tiwari headed a committee which had analyzed the legitimate and different
challenges looked by banks and budgetary foundations and proposed healing measures
incorporating changes in law. The Tiwari Committee had additionally recommended setting
up of specialized courts for recuperation of duty of the banks and money related
organizations by following an outline methodology. So, the Recovery of Debts Due to Banks
and Financial Institutions Act 1993 in short DRT Act was passed. Keeping in consideration
with the worldwide patterns on helping budgetary foundations recoup their awful obligations
rapidly and productively, the Government of India has constituted thirty three Debts
Recovery Tribunals and five Debts Recovery Appellate Tribunals the nation over.
Establishment of the Debt Recovery Tribunal
Before institution of the Debt Recovery Tribunal the banks were in a predicament before the
advent of the Debt Recovery Tribunal. Debt recovery cases were like other civil cases and
had to be filed in ordinary civil courts. Court proceedings were dragged for long periods, at
times more than 15 years. This took its toll on the financial health of the banks, as the chunk
of the stressed assets got snagged in the litigation. The bank found it very difficult to fund
their further advances. This grave situation led the economy into the trajectory of sluggish
growth. Industry found it tough to get credit to fund projects. The Government then appointed
the Narasimhan Committee, which made a path-breaking recommendation to install tribunals
to deal with cases of debt recovery.1

The need for a comprehensive law on the recovery of debts was stressed by the Tiwari
Committee Report (1981) which stated: “The civil courts are burdened with diverse types of
cases. Recovery of dues due to banks and financial institutions is not given any priority by
the civil courts. The banks and financial institutions like any other litigants have to go
through a process of pursuing the cases for recovery through civil courts for unduly long
period.”2

The Tiwari Committee Report was endorsed by the Narasimhan Committee in

1991.Conforming to the recommendations of Narasimhan Committee, the Government in
1993 enacted the avant garde legislation of Recovery of Debts to Banks and Financial
Institutions Act (Popularly known as the RDB Act). The functions of the Debt Recovery
Tribunal were governed by the RDB Act. It has to be noted that the Tribunal was set up by an
Act of Parliament, which is empowered to do so according to the Article 247 of the
Constitution of India. The RDB Act revolutionised the way asset-recovery cases were
resolved in India. It has been challenged in various accounts. In 1995, the constitutionality of
the DRT was challenged successfully before the Delhi High Court, which held that the
Tribunal could not function validly since it did not have any provision for filing
counterclaims.3 Subsequently, the RDB Act was amended and the constitutionality of the

1
See, the Tiwari Committee Report, 1981.
2
ibid
3
Mukesh Dwivedi,Debt Recovery Tribunals in India: The Legal Framework,Indian Journal of Law and Policy
Review pp. 46-65
amended act was upheld by the Supreme Court. As things stand now, borrowers are entitled
to file ‘counterclaims’ under S.19 of the RDB Act.4

The Debt Recovery Tribunals (hereinafter referred to as the ‘DRT’) are established following
the Recovery of Debts due to Banks and Financial Institutions Act, 1993.5 The DRTs are
located across the country. Some cities have more than one Debt Recovery Tribunal located
therein. One DRT each has been constituted at Ahmadabad, Allahabad, Aurangabad,
Bangalore, Chandigarh, Coimbatore, Cuttack, Ernakulum, Guwahati, Hyderabad, Jabalpur,
Jaipur, Lucknow, Nagpur, Patna, Pune, Ranchi and Vishakhapatnam. Depending upon the
number of cases a Debt Recovery Tribunal is constituted.

There are a number of States that do not have a Debt Recovery Tribunal. The Banks and
Financial Institutions and other parties in these States have to go to Debt Recovery Tribunal
located in other states having jurisdiction over their area. Thus, the territorial jurisdiction of
some Debt Recovery Tribunal is very vast. For example, the Debt Recovery Tribunal located
in Guwahati has jurisdiction over all the seven North Eastern States. Similarly, the territorial
jurisdiction of the Debt Recovery Tribunal located at Chandigarh too has a very wide
jurisdiction over the States of Punjab, Haryana and Chandigarh.6

The setting up of a Debt Recovery Tribunal is dependent upon the volume of cases. Higher
the number of cases within a territorial area, more Debt Recovery Tribunal would be set up.
Each Debt Recovery Tribunal is presided over by a Presiding Officer. The Presiding Officer
is generally a judge of the rank of Dist. & Sessions Judge. A Presiding Officer of a Debt
Recovery Tribunal is assisted by a number of officers of other ranks, but none of them need
necessarily have a judicial back ground. Therefore, the Presiding Officer of a Debt Recovery
Tribunal is the sole judicial authority to hear and pass any judicial order. 7 Each Debt
Recovery Tribunal has two Recovery Officers. The work amongst the Recovery Officers is
allocated by the Presiding Officer. Though a Recovery Officer need not be a judicial Officer,

4
See, Section 19 of the DRT Act, 1993
5
See Section 3 of the Recovery of Debt Due to Banks and Financial Institutions Act, 1993.
6
Abhijit Lele,Banks flag 'tardy' work, piling-up of cases at debt recovery tribunals, Business Standard
https://www.business-standard.com/article/economy-policy/banks-flag-tardy-decision-making-piling-of-cases-
at-recovery-tribunals-119032300883_1.html last assessed on 2nd September 2019
7
See, Section 4 (1) of the Recovery of Debt Due to Banks and Financial Institutions Act, 1993
but the orders passed by a Recovery Officer are judicial in nature, and are appealable before
the Presiding Officer of the Tribunal.8

The Debt Recovery Tribunals are governed by the provisions of the Recovery of Debt Due to
Banks and Financial Institutions Act, 1993 (hereinafter referred to as ‘RDDBFI Act, 1993),
also popularly called as the RDB Act. Rules have been framed and notified under the
Recovery of Debts Due to Banks and Financial Institutions Act, 1993.

Laws of Debt Recovery Tribunal

The Debt Recovery Tribunal have been constituted under Section 3 9 of the Recovery of Debts
Due to Banks and Financial Institutions Act, 1993. The original aim of the Debts Recovery
Tribunal was to receive claim applications from Banks and Financial Institutions against their
defaulting borrowers. For this the Debts Recovery Tribunal (Procedure) Rules 1993 were also
drafted.

While initially the Debts Recovery Tribunals did perform well and helped the Banks and
Financial Institutions recover substantially large parts of their non-performing assets, or their
bad debts as they are commonly known, but their progress was stunned when it came to large
and powerful borrowers. These borrowers were able to stall the progress in the Debts
Recovery Tribunals on various grounds, primarily on the ground that their claims against the
lenders were pending in the civil courts, and if the Debts Recovery Tribunal were
adjudicating the matter and auction off their properties irreparable damage would occur to
them.

The dues of work men against a company, the State dues, and the dues of other non-secured
creditors all got enmeshed before the Debt Recovery Tribunals. As if these were not
sufficient, there was clash of jurisdiction between the Official Liquidators appointed by the
High Courts and the Recovery Officers of the Debts Recovery Tribunals. The Official
Liquidator, an appointee of a superior authority, took into his possession all the properties,
which actually belonged to secured creditors who before the Debts Recovery Tribunal. The
High Courts also took umbrage on the activities of the Recovery Officers who give away the
entire amounts and paid off to the banks leaving nothing for the other claimants, including the
work men. All these and other issues lead to drastic amendments to the Recovery of Debts
Due to Banks and Financial Institutions Act by means of an amending notification in the year
8
ibid
9
Section 3 of the Recovery of Debt Due to Banks and Financial Institutions Act, 1993
2000.10 The Debts Recovery Tribunal has to deal with extraordinary complex commercial
laws within the narrow ambit of the two laws. Over the years the Debts Recovery Tribunals
have evolved into fine bodies with lot of expertise. There is a plethora of judgments from the
Supreme Court as well as the various High Courts which have paved the way of the Debts
Recovery Tribunals to chart their courses. The Debts Recovery Tribunal of India have
become model institutions for many a country to follow.

10
See, http://bankdrt.net/auction_rules.php last assessed on 2nd September 2019
Constituents of a Debt Recovery Tribunal
A Debt Recovery Tribunal is headed by a Presiding Officer, who acts as the Judge of the
Tribunal. It also consists of a number of staff in the Registry. The Registry is responsible for
accepting applications and filing of cases with the DRT. The Registry is headed by a
Registrar. It is the Registrar’s mandate to perform the functions of a Judicial Officer till the
case is transferred to the Presiding Officer for the final hearing. The Registrar is assisted by
an Assistant Registrar. The Act also accounts for the post of Recovery Officers who are to
execute the decree.

Duties and Powers of the Recovery Officer11

i. Execute the final decree

ii. Post the final decree, to realise the debt amount and deposit it back with the bank.

iii. Conduct public auction according to Section 25 to 28 of the RDB Act.

iv. The merits of the Certificate, or the amounts mentioned in the Certificate cannot be
agitated before the Recovery Officer.

v. The Recovery Officer does not have the powers to add or remove people whose onus it is
to satisfy the certificate. The Recovery Officer can, however, enlarge the area of persons
from whom he may attempt to satisfy the Certificate, subject to provisions of the Rules, i.e.
the new persons must be holding sums on behalf of the Certificate debtor.

Duties of the Registrar

i. Registry accepts all the original applications and securitisation applications, and files them.

ii. The Registry passes the file to the Registrar, who performs further scrutiny.

iii. He performs the initial functions of the Tribunal in the primary stage of the course of
action.

iv. The Registrar has the duty to issue summons, Show-Cause Notices and make the
defendants aware of the suit filed against them.

v. The Registrar also collects the reply to the issued Show-Cause notices.
11
Section 19 of the Recovery of Debts to Banks and Financial Institutions Act,1993
Procedures followed by the Debt Recovery Tribunal

i. Section 19 of the RDB Act deals with the procedure for filing a case with the DRT.

ii. An application can be filed in the Tribunal on a case, within the jurisdiction of it, on the
recovery of debts from a person or an entity.

iii. If two or more banks have a case on the same matter, the latter banks can join the former
or first bank (on the filing of application).

iv. A fee is prescribed by the Act, which shall be paid by the applicant. The minimum fees to
file an application is 12,000 and the maximum is 1,50,000.

DRT Proceedings in a Nutshell

Followings are the proceedings for the Tribunal:

i. An original application along with the documents of evidentiary value and the required fees
is filed with the Registry.

ii. The Registry reviews the application, checks for any flaws, accepts or rejects it.

iii. The file then passes to the Registrar for further scrutiny of the application.

iv. If the application is registered, a summons is issued by the Registrar.

v. If the defendant does not appear, the case becomes ex-parte.

vi. Else, the defendant is required to file a Written Statement within 90 days of the summons.

vii. Proof-Affidavit is filed by the applicant.

viii. A Hearing Date is set by the Registrar under the directions of the Presiding Officer.

ix. A Stay Petition may be served by the defendant.

x. Counter-Proof Affidavit is filed by the defendants.

xi. Final Hearings on the case will be done

xii. The Final order or decree is made by the Presiding Officer.

xiii. A Recovery Certificate made by the Tribunal will be passed on to the Recovery Officer
of the Tribunal who has the responsibility of recovering the amount and hand it over to the
bank.

Facts Concerning Procedure Followed by the DRT12

i. On receipt of an application, the Tribunal shall issue summons, requiring the defendant to
show cause within 30days of the service of summons as to why the relief prayed for should
not be granted.

ii. A Counter-claim can be filed by the applicant through a written statement against the
application and the acts of the applicant, attached with the necessary documents of
evidentiary value.

iii. Section 19(12) provides that the Tribunal shall give an interim order in the form of an
injunction, stay or attachment.

iv. The tribunal can appoint a Receiver.

Section 19 of the RDB Act clearly lines up the procedure to be followed, initially by the
applicant and then by the Tribunal in the process of dispensing cases.

Debt Recovery Appellate Tribunal13

The Debt Recovery Appellate Tribunal is also established as a result of the Recovery of
Debts due to Banks and Financial Institutions Act, 1993. The DRAT has the appellate
jurisdiction on all matters concerning the recovery of debts in India. There are currently 5
DRATs in India. They are in Mumbai, Delhi, Chennai, Kolkata and Allahabad. The Judge in
a DRAT is addressed as Chairperson. An appeal can be made against a decision by the DRT
within 45 days from the date of passing of the decree, by depositing 75 per cent of the claim
or any such amount as fixed by the DRT.

12
Section 19 Recovery of Debts to Banks and Financial Institutions Act,1993
13
See section 9 of Recovery of Debts to Banks and Financial Institutions Act,1993
Judicial decisions
As to the leave of the Company Court for transfer of cases, one of the earliest cases where the
aspect of the overriding effect of the Act was faintly mentioned was in Industrial Credit and
Investment Corporation of India Ltd v. Srinivas Agencies 14, where the issue of whether leave
should be granted by the Company Court to continue proceedings in other civil courts and
whether all proceedings should be transferred to the Company Court. The court was of the
view that the approach to be adopted by the Company court does not deserve to be put in a
straightjacket formula. The discretion to be exercised has to depend on the facts and
circumstances of each case. While exercising this power, the Company Court should also
bear in mind the rationale behind the enactment of the Act.

The non-obstante clause:

The non-obstante clause in the Act and the non-obstante clause in the Companies Act were
considered in Industrial Credit and Investment Corporation of India Ltd v. Vanjinad
Leathers15 where the court opined that Section 18 of the Act creates a bar on jurisdiction of
other authorities and courts except the Supreme Court and High Courts under Articles 226
and 227 of the Constitution. The court also stated that the Act and the Companies Act is
special legislation. However, since the Act was enacted after the Companies Act, 1956, the
Parliament would have certainly in mind the provisions in the earlier special law namely the
Companies Act. Therefore, the latter special law will prevail over the former.

Courts have, from time to time, considered the effect of a special act enacted subsequent to a
general act or a special act. The Supreme Court in Life Insurance Corporation of India v. DJ
Bahadur & Ors.,16 held that the ‘legislature has an undoubted right to alter a law already
promulgated by it through a subsequent legislation. A special law may be altered, abrogated
or repealed by a later general law through an express provision. A later general law will
override a prior special law if the two are so repugnant to each other that they cannot co-exist
even though an express provision is not provided for in that general law.’

It is only in the absence of an express provision to the contrary and of a clear inconsistency
that a special law will remain wholly unaffected by a later law.

14
(1996) 86 Comp Cas 255 (SC).
15
AIR 1997 Ker 273.
16
(1981) 1 SCC 315.
The general rule to be followed in case of a conflict between two statutes is that a later statute
abrogates the earlier ‘leges posteriors priores contrarias abrogant’ and the well-known
exception is that general legislations do not derogate special legislations ‘generalia
specialibus non derogant’.

The Supreme Court held in JK Cotton Spinning and Weaving Mills Co. Ltd v. State of U.P.,17
that when there is a conflict between a specific provision and a general provision, the specific
provision prevails over the general provision. The rule applies to resolve conflicts between
different statutes as also in the same statute.

The Patna High Court in Bihar Solex (P) Ltd.,18 on the basis the judgment in Maharashtra
Steel Tubes case held that u/s 17, 18 and 34 there cannot be any doubt that the jurisdiction of
the DRT to entertain and decide suits or other proceedings by banks or financial institutions
is exclusive, to the exclusion of all other courts except the Supreme Court or the High Court
under Articles 226 and 227.

The Supreme Court in the Industrial Credit and Investment Corporation of India Ltd case
held that there was no requirement of the leave of the leave of the Company Court for any
party to proceed in the DRT and that has to be tried in the specialised machinery set up under
the Act.

Another question that came before the High Court of Calcutta in State Bank of India v. S.M.
Oil Extraction (P) Ltd.,19 was whether the non-obstante clause contained in a different
enactment that is the Act would operate to deprive or deny those rights of creditors or
workers in a Company in liquidation, which were protected under the Companies Act. The
Court held that the provisions of the non-obstante clause in the Act would have no effect on
the procedure as contained in the Companies Act. Consequently, there would be no conflict
in the operation of the two clauses. For it was on record that section 446 of the Companies
Act was not repealed and it could not be said with any certainty that there appeared any
intention of the legislature anywhere in either of the enactments, that the later enactment
would in effect operate as against the earlier clause. Had the legislators so intended, indeed
appropriate provisions to that extent would have been provided for in the later or in further
legislation. In those circumstances, it was held that when the rights of the creditors and
workers were protected by the legislators in the Companies Act, in the absence of any
17
[1961] 3 SCR 185, 194.
18
(1999) 20 Com Cas 235 (Bihar).
19
(1999) 21 Comp Cas (Calcutta).
specific and categorical provisions a, non-obstante clause contained in a different enactment
neither could nor operate to deprive or deny any such right.

A lot of issues came for discussion in Allahabad Bank v. Canara Bank20. The issues included
jurisdiction of the tribunal and the Recovery Officer under the Act, need for the leave of the
Company Court, power of the Company court to stay proceedings under the Act, whether
banks filing for recovery can appropriate the entire sales proceeds realized except to the
limited extent restricted under section 529A of the Companies Act, position of secured
creditors who participate in the winding up proceeds and those who opt to stand outside the
winding up proceedings.

The jurisdiction of the tribunal with respect to adjudication was held to be exclusive. The
court observed that basically the tribunal is to adjudicate the liability of the defendant and
then it has to issue a certificate under Section 19(22) of the Act, which was recently amended
by Ordinance 1 of 2000. Under Section 18 of the Act, the jurisdiction of other courts (except
that of the Supreme Court and High Courts under Articles 226 or 227 is completely ousted
and the power to adjudicate is exclusively vested in the DRT.

Similarly, regarding 'execution' the jurisdiction of the recovery officer is exclusive. The
Tiwari Committee, in its report mentioned that the exclusive jurisdiction of the Tribunal must
relate not only to the adjudication of liability but also to the execution proceedings.

The next issue was whether the leave of the company court is required for continuing or
initiating proceedings in the DRT and whether the Company Court could stay proceedings in
the DRT. Questions also arose with respect to priorities under Sections 529, 529A, and 530.
Reliance was placed on the judgment of the Supreme Court in Valji Shah v. LIC of India,21
where the analogy between s.18 of the Act and s. 41 of the Life Insurance Corporation Act
was brought out and the court held:

" ...just as the Company Court was held incompetent to stay or transfer and decide the claims
before the LIC tribunal because the Company Court could not decide the claims before the
LIC tribunal, the said court cannot decide the claims of banks and financial institutions. On
parity of reasoning with the Valji Shah case, there is no need for the appellant to seek leave
of the Company Court to proceed with its claim before the DRT or in respect of the execution
proceedings of the recovery officer. Nor can they be transferred to the Company Court."
20
AIR 2000 SC 1535.
21
AIR 1966 SC 135.
It further held that the Act and the special provisions in it were for a superior purpose, i.e., the
provisions of the act are superior to the provisions of s 442, 446, and 537 of the Companies
Act. As far as priorities for creditors are concerned, the Tiwari Committee had stated, "the
Adjudication Officer will have such power as to distribute the sale proceeds to the banks and
financial institutions being secured creditors in accordance with inter-se agreements or
arrangement between them and to other persons entitled thereto in accordance with the
priorities in Law." The above recommendations have been brought in to the act with greater
clarity under Section 19(19) as substituted by Ordinance 1 of 2000.

Conclusion and Suggestions

Banks have expressed their dissatisfaction with the system that was instituted to ensure speedy
recovery. The number of claims in litigation is quite large and changes should be made urgently to
revamp the existing model. Unless the system is overhauled, the rate of pendency at the Tribunal will
rise unrestrained. Such a state of affairs will seriously put the banking system in doldrums. The
functioning of Debt Recovery Tribunals (DRTs), created to help financial institutions recover dues
speedily without being subjected to the lengthy procedures of usual civil courts, appears to cause
more pain than gain for banks.

As to the suggestions to improve the debt recovery scenario in the country it is recommended that the
time bound disposal of cases though the Court has to dispose an order application within six months,
and a stay application within two months from the date of its admission, this has not been followed by
the Tribunals in India in many situations. The government has to make sure that time-bound disposal
of the cases is done mandatorily by adding the clause in the Act and making it a law. Even though the
SARFAESI Act has mandated the Debt Recovery Tribunals to settle the Original Applications within
six months, this is not obeyed strictly. Efforts have to be taken to ensure this.

Bibliography
Statutes

1. Recovery of Debts to Banks and Financial Institutions Act,1993

Reports

1. Tiwari Commitee, 1981

Book

1. M L Tannan, Banking Law, 26th edition

Newspaper report

1. Abhijit Lele,Banks flag 'tardy' work, piling-up of cases at debt recovery tribunals,
Business Standard

https://www.business-standard.com/article/economy-policy/banks-flag-tardy-decision-
making-piling-of-cases-at-recovery-tribunals-119032300883_1.html