Legalising Defamation of Delinquent Borrowers: Disregarding the Constitution and the

Law
Author(s): SHAMBA DEY
Source: Economic and Political Weekly , SEPTEMBER 6, 2014, Vol. 49, No. 36
(SEPTEMBER 6, 2014), pp. 62-66
Published by: Economic and Political Weekly

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NOTES

Legalising Defamation
In 2006, the case of K J Doraiswamy3
raised the question as to whether or not
a secured creditor, who/which has initi
of Delinquent Borrowers ated action for enforcement of its securi
ty interest in terms of the provisions of
Disregarding the Constitution and the and
the Securitisation Law
Reconstruction of
Financial Assets and Enforcement of
Security Interest (sarfaesi) Act, 2002,
SHAMBA DEY is entitled to publish the photographs of
the defaulting borrowers or guarantors
In their attempt to ensure in newspapers or magazines. The Court
information about defaulting bor held that
speedy recovery of loans,
Banksrowers
in since
India
early have been publishing
2013 through If borrowers could find newer and newer
banks in India have begun
regular advertisements in print media, methods to avoid repayment of the loans,
publishing photographs detailing names, addresses and photo the Banks are also entitled to invent novel
methods to recover their dues.
and details of defaulting graphs of the defaulting persons. Many
Further, it was held that from the
borrowers. It has proven ofto
these be
persons are retail borrowers,
students, consumers, homebuyers or point of view of the individual, his right
an effective method of putting
owners of small and medium enterprises. to privacy is not absolute and from the
social pressure on defaulting
Other borrowers are companies. Both point of view of the bank, the duty to
borrowers. However, it isthese categories of borrowers default maintain secrecy is superseded by a
on their loan obligations quite often.
argued that the act of publishing larger public interest as well as by the
When that happens, the lending banks bank's own interest under certain
details and photographs of circumstances.
publish such personal information, along
borrowers in public fora with
is photographs,
not in the print media. The judgment of the Madras High
The
only extrajudicial, but that it State Bank of India and several Court has put into sharp relief the rights
other
fundamentally violates the banks, in order to make speedy
rights of the defaulting borrower vis-à-vis the
recoveries of their loan amounts, have
right of the banks or financial institutions
of borrowers.
used this practice to exert social pres
to recover public money. However, the
sure on defaulters. At least one bank judgment is lacking in many aspects.
official has claimed that this method is First, there are many valid reasons
indeed effective in accelerating recoveries for a person to default on his obliga
from defaulters.1 tions against a home loan, an education
However, as is apparent, this practice loan or a business loan. There is noth
has been criticised to be prima facie an ing immoral about it, neither is such a
act of defamation against the borrower default in payment an offence under
by the banks, and the right of banks to the Indian Penal Code 1870, but a sim
adopt any method for the recovery of ple civil offence and therefore a draco
its dues, including the publication of nian extrajudicial step to mentally and
the photograph of the defaulter hasmorally punish the borrower is an act
come directly into conflict with the against the conscience and spirit of
right to privacy and dignity of the bor the law.
rower, which has now come to be recog Second, the Court disregarded the
nised, to some extent, as part of the possibility that by giving a bank the
right to life guaranteed under Article 21 freedom to publish a photograph, an act
of the Constitution. But the governof defamation is committed by the bank,
ment, the Reserve Bank of India (rbi) causing damage to the personal and pro
and several courts have not raised any fessional reputation of the borrower, but
objections in this matter, whereas leaving the borrower without a remedy
some others have.2 This case commen against such violation. This gives banks
tary discusses the reasonableness of
the legal sanction to violate the bor
theispositions
Shamba Dey (s.dey.8788@gmail.com) a taken by different high
rower's fundamental right to human
student of law at the University of Mumbai and
courts regarding this practice that isdignity.4
a It was argued and accepted by
specialises in banking and finance cases.
rising trend. the Court that under Section 499 of the

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 NOTES

Indian Penal Code 1870, an exception to questionable as to what duty is owed by novel methods to defraud
defamation is provided wherein it is not the banker to the public, other than be- Consider a simple example
defamation if done for public good, ing able to repay the public's deposits who is a natural person, will al
However, this argument cannot be said when demanded. It is common sense to devise new methods t
to hold in a private contractual relation- that in the business of banking, some police or the courts but th
ship between the bank and the borrow- borrowers will default. This is the very give the latter public autho
er. There is no public good being violât- essence of banking - a banker, who is permission to employ extrale
ed by a mere breach of contract. also an individual, may misgauge or to make the convict toe their
Third, the publication of photograph overestimate the future financial condi
is a violation of the borrower's right to tion of the borrower. Every bank's busi- Individuals versus Instit
privacy and of bank secrecy laws.5 ness is exposed to such credit risk, just One possible reason why
In Halsbury's Laws of England, it is as an insurance company or public com- High Court has favoured ban
stated that panies that are also using public money matter is probably because in the past,
It is an implied term of the contract between are exposed to downside risks. It is un- there have been many instance
a banker and his customer that the banker reasonable for bankers to expect that the ful defaults by borrowers. Furth
will not divulge to third person without the bank will be shielded perpetually has been a sharp increase in the
express or implied consent of the customer against all risks and that they may go to age of non-performing asse
either the state of the customer's account . . . .. . . . . T 1 r u 1 n. 1 jc . , . . .
., , , . any extent to serve their interests. Lack of books of bank
or any of his transactions with the bank or
any information relating to the customer bankruptcy protection for consumers w
acquired through the keeping of his account result in "risk-free" loans for creditors, r
unless the banker is compelled to do so by moving pressure on creditors to nego
order of a Court or the circumstances give iower payments. ever, the
rise to a public duty of disclosure or protec- jt js true ^at non-performing ass
tion of the banker s own interest requires it.6 r 0 ,,, ,r , , r ,
are a cost to the economy as was rightly defaulter is a w
In Tournier vs National Provincial and observed by the Supreme Court i
Union Bank of England7 it was held that Transcore vs Union of India10 and it is
under four heads, the bank could disclose therefore, the duty of public sector
such information, namely, (a) where the banks to reduce such cost by resortin
disclosure was under compulsion by law, every possible legal means; in order
(b) where there was a duty to the public ensure that banks remain solvent and
to disclose, (c) where the interest of the perform their duty to the public who
bank requires disclosure, and (d) where vests their deposits with the banks, f
the disclosure was made by express or there are several methods of recovery
implied consent of the customer. laid down in the law. Section 13(4) of t
Along the same lines, the Supreme sarfaesi Act has given wide and suffi- re
Court has held in Sharda vs Dharmpal8 cient powers to banks to enforce thei
that security interests and recover dues from retail borrower does not and therefore
...The right to privacy in terms of Article 21 borrowers by taking possession. Under the presumption that a borrowe
of the Constitution is not an absolute right, tjje SARFAESI Act, banks do not need to a home loan or an education loan1
If there were a conflict between the Funda- , . . , , , , , . ... ,, , .
mental Rights of two parties that right which take a defaulter to court in order
advances public morality would prevail. possession but may only serve a noti
a borrower and thereafter take neces- Furthermore
Banks' Public Duty sary action. to borrowers, there is an implicit rela
In Kattabomman Transport Corporation Despite such provisions in place, per- tion of trust between th
Ltd vs State Bank ofTravancore,9 the Ker- mitting an extrajudicial method puts a obligations will be h
ala High Court ruled that in cases where question mark on the Court's wisdom. It this trust, the loa
public funds are involved, the bank's is well settled that the state or its execu- ever, a failure to perfo
public duty would prevail over its pri- tive officers cannot interfere with the cannot straightaway
vate duty to the customer. Whereas the rights of its subjects unless they could borrower cannot be tr
Madras High Court laid emphasis on the point to some specific rule of law autho- the future. Publishin
apex court's judgment in the Sharda rising the act of interference. A bank, newspaper in effect con
case, but in KJDoraiswamy's case it may which is a public authority, has to act message to the public,
not be correct to say that a public display within the boundaries of law and a court in public interest. S
of the photograph of the defaulting bor- cannot allow the secured creditor to sub- not disclose whethe
rower protects public morality or serves vert the law simply because a borrower, disputed by the b
the interests of the public. It is also who is a natural person, is inventing essence defeats the rights

Economic & Political WEEKLY E323 SEPTEMBER 6, 2014 VOL XLIX NO 36 b3

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NOTES

under Section 17 of the sarfaesi Act, borrowers had been challenged in two High notified in terms of the sta
and are therefore incomplete pieces of Courts (Madras and Madhya Pradesh) in the by issuance 0f notices in n
, , recent past and in both cases the courts had . . . 1
information that are passed on to the upheld the action of banks
public at large. newspaper advertisement (giving kno
It was again in the case of S T Tamil address, photographs etc) on
Selvi,13 that the Madras High Court held efforts to serve notices unde
.h,, the mode of publica.ion of phofo- ™These °f b™k'
graph of defaulting borrower cannot be they have opined that banks exercise utmost are displayed outside th
taken to be an act of coercion. The Court care while dealing with this sensitive issue, set, are not entirely defam
observed that if at all, taking into con- while publishing photos of borrowers along acter because these not
sideration that the loan is granted in wi± notices issued under sarfaesi Act of cautjonary; intended to inf
, „ , , wilful defaulters/fraudsters etc could be . ,1.1
2006 and till 2012, it was not settled and Justifiedj it may not be des
having now only called upon to pay and publishing photographs of de
only thereafter if the borrower fails to ers merely for the reason
do so, then publishing cannot be stated standing and as a matter of r
.... . be added that the sarfaesi Act, 2002 does , f . , ,
as coercive step to collect the loan. Ac- not mention abouf publication of photo.
cordingly, the high court dismissed the graphs of defaulters. The Possession Notice
Writ Petition of Certiorari. provides for description of the immovable
While this judgment has given the property more as a caution to the public at
State Bank of India more encourage- large not to deal with the property and any
such dealings with the property will be sub- . . .
ment in its efforts to publish the photo- ject t0 the charge of the Secured Creditor. cutta HlSh Co
graphs of borrowers who have default- We, therefore, concur with the views of iba Ujjal Kumar D
ed, the question that comes to mind im- in the matter that publishing of photographs and Messrs Al
mediately is that if such publication is of defaulters should not be resorted t0 as a Limited vs Th
, . . matter of routine and utmost care is to be _ . . . ,. _ ,
not coercive and does not in any way exerdsed whUe dealing wkh ^ s
force the borrower to pay up the due issue you are requested to take ne
amounts, then there is no necessity to action in this regard. c
publish the personal infallibilities of the However in the absence of any
borrower and violate the right to privacy press legislative provision or ne
of the borrower. In another case, Ku implication to defame the defa
Archana Chauhan,14 it was held by the borrowers, the central banker ma
Madhya Pradesh High Court, in unam- be said to have issued a word of a
biguous terms, that the publication of to the banking community rather
photographs of the defaulting borrowers strict direction. Thus the letter
is not prohibited by the sarfaesi Act central bank cannot be said to hold
and, therefore, cannot be held to be im- substantial force and cannot be
permissible and that it is neither arbi- upon by courts in allowing bank
trary or illegal, and nor is it defamatory. defame borrowers. The public m
Further, banks and their counsels have
placed reliance upon a letter written by the EPW E-books
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that publishing of photographs of defaulter

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the secured asset under Section 13(4) of The question here is not just limited to action of a bank "on the ground of viola
the Act read with Rule 8,17 the secured whether or not banks have the authority tion of fundamental rights of loanees".
creditor would be encouraged to use pri- to publish a defaulting borrower's photo- But another case decided by the Bom
vate forces, such as musclemen, to dis- graph but whether it precludes a court bay High Court has put a dent by ruling
possess the borrower. Even employing from passing an order allowing an act against the judgments of the Calcutta
musclemen to recover a loan is not ex- that is not expressly provided by the law. and Kerala High Courts, without justify
pressly barred by law. But these addi- The general rule of thumb is that courts ing why it differed from the opinions ex
tional procedures for enforcing security should be very careful when sanctioning pressed by the other courts. In the case
are not contemplated in the sarfaesi an Act19 that is not provided for in the of DJ Exim (India) Pvt Ltd vs State Bank
Act. If the legislature felt the need for in- law and should pass wise and qualified of India,21 it was admitted that D J Exim
eluding such measures in the Act, it decisions, taking into consideration the was unable to pay the amount which
could have done so. If a court allows facts and circumstances of the case and was due to the bank and the proposal for
such additional procedures, it only the implications of its decision. restructuring of the secured land has
means that "the secured creditors would also been given by the company to the
have the carte blanche to invent any Damaging Reputations State Bank of India. It
method for recovery of their secured In this regard, the Calcutta High Court that the company
debt throwing asunder the provisions of commented that unintended damage question of whethe
the sarfaesi Act."18 that could be caused to the reputation of ful or not was not given due considera
The Calcutta High Court in its judg- an honest borrower by way of publica- tion, although the bank contended in an
ment also made some pertinent remarks tion of his photograph and that such affidavit that the company had commit
about the sarfaesi Act. It noted that the damage could be irretrievable and it ted various acts of misfeasance (which
Act confers wide powers on the secured may not be possible to compensate the were disputed by the company). In para
creditors to enforce the security interest borrower by awarding only monetary 11, the judgment stated:
without judicial intervention up to the compensation, if the borrower, who has ., ,the bank has the right to publish the name
point of taking any of the measures been proceeded against contrary to law of the defaulters by giving their names and
mentioned under Section 13(4) thereof, by the secured creditor and whose pho- addresses and two fold purpose is served as
Classification of a loan account as non- tograph is published, is unable to bear a result of the said publication of the names,
, . . ... . , , ,, firstly the fact that these persons are wilful
performing asset, computation of the the humiliation and takes a regrettably defaulters
amount of dues and taking possession of drastic step. Since publication of photo- iarge and
the secured asset upon rejection of the graph of a defaulting borrower exposes the prospe
response to the notice under Section 13(2) him to irreparable loss and prejudice, the prope
are the various steps that can be taken by publication of photograph cannot be re- defaulters
the bank for enforcing its security interest sorted to in the absence of an express The Co
against the borrower and in doing so, power or an agreed term in this behalf. addition
the secured creditors do not ordinarily It is only in very serious cases of wilful tion of ph
face interference from the courts. and mala fide default that such measures we are als
It is only at the stage when Section may be considered by a court to punish every case
17(1) is invoked that there is scope for a the borrower and whether such meas- a, Wll[ul d
, , , j . the photographs in a routine manner and
judicial determination of the issues ures should be resorted to in se
raised by a borrower by the Debts Recov- cases is also debatable. The M
ery Tribunal. Until the Tribunal is ap- Madhya Pradesh High Courts
proached and a prayer is submitted for have considered the excess
interim relief, it is totally a one-sided af- their judgments have co
fair for the banks and the borrower has secured creditors to publish
no recourse. A borrower can approach a of borrowers at their w
Debts Recovery Tribunal under the law, Justice V Chitambaresh of t
, . , , , r . ,. - j ... not only wilful defaulters but had commit
but that can be done only after the credi- High Court- also re
tor initiates action and attaches proper- and illegal the move by th
ty. The tribunal could go into the merits India to publish photogr
of the case and could also rule in favour faulters. The judge said th
...... , , r defaulters should be published or not. In
of the borrower. But that is a time- tice of exhibiting a photograph of a per- presenj c
consuming affair, as tribunals often take son and shaming him in public for the that afte
months and years to dispose of cases, sin of being in an impecunious condition about the
, , .. , , j • tioner bank, the Senior Executive officer
Where the secured creditor has such cannot be encourag
workable methods at its disposal, the ties like ours and th
necessity of defamation does not arise. "not (be) stopped
Economic & Political weekly iHiàïi September 6, 2014 vol xlix no 36 65

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NOTES

Majesty's Court of Appeal in England (1 KB 461

be compared to the practice of swift,
This, in effect, gives banks the decision
at 472).
making power regarding whether or harsh
not and unusual punishment seen inwas decided by the Supreme Court of
8 The case
some African and west Asian tribes
a defaulter wilfully defaults and accord India in 2003 (4 SCC 493).
9 A case decided by Kerala High Court in 1992
ingly publish their photograph. Not and
onlyin early puritan settlements of
(AIR 1992 Kerala 351).
America.
banks, but any person or entity who has It is not consistent with the 10 The case was decided by the Supreme Court in
failed to receive payment due from
legislative intent of the sarfaesi Act or 2007 (AIR 2007 SC 712).
11 In a 1972 case between S, SW and the Official
another person or entity can labelany
such
other law. Liquidator, the English Court held that the
breaching person or entity as a wilful Court had no power to order a blood test on the
ground that it would be a battery which no
defaulter and publish the photograph, court may authorise.
on the reason that there is nothing
1 See Manish Basu (2013), Banks Name Defaulters, 12 The Government of India has directed banks

defamatory about it and that thereBut

is Hesitate on Publishing Photos", Mint, not to publish photographs of education loan
5 September. defaulters.
no express provision of law debarring
2 The All-India Bank Employees Association has13 ST Tamil Selvi vs State Bank of India, SARB,
such publication. urged the Government of India to publish Chennai, Writ Petition No 199 of 2012-MP No 1
names of all loan defaulters who owe banks of 2012.
It is well settled and need not be reit more than Rs 1 crore and to make wilful de 14 The case was argued between Archana Chau
erated that recovery has to be made as fault a criminal offence. See, "Expose Default han and State Bank of India in the High Court
ers Who Owe Banks over Rs 1 Crore, Union of Madhya Pradesh (AIR 2007 Madhya Pradesh
per the law and not by acts of force, co
Tells Government", The Hindu, 24 November 45)
ercion, or defamation. The usage of a 2013. 15 Writ Petition No 10315 (W) of 2013.
borrower's photograph, originally ob 3 Mr K J Doraisamy vs The Assistant General 16 Writ Petition No 9850 (W) of 2013.
Manager, State Bank of India, Writ Petition17 Under Rule 8, the bank has a right to publish
tained for mere purpose of banking No 17761 of 2006. the names and addresses of the directors and
records, for public opprobrium is not an
4 Justice Subbarao, in Kharak Singh vs State of guarantors if they have defaulted in payment
Uttar Pradesh, held that nothing is more delete of the loan amount.
ethical practice. The documents execut
rious to a man's physical happiness and health18 Judgment of Calcutta High Court, refer to
ed by borrowers relate only to different than a calculated interference with his privacy. notes 14 and 15.
legal actions to be taken in case of5 See Shankarlal Agarwalla vs State Bank of India 19 A1968 case in England (B R B vs B, (1968) 2 All
default and do not accede to such AIR 1987 Calcutta 29 (holding that banker is ER-1023).
under an obligation to secrecy). 20 Writ Petition No 10864 of 2013 and Writ Peti
practices. Default is a civil wrong and Edition, Volume 3, page 72, Article 97.
6 Fourth tion No 20686 of 2013.
employing such practices can only 7 A landmark legal case decided in 1924 by Her 21 Writ Petition (L) No 2808 of 2013.

Environment,
Environment, TechnologyTechnology
and Development:and D
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