VidhiSangh

Supreme Court of India · 15/09/2025

ASSISTANT GENERAL MANAGER STATE BANK OF INDIA & ANR. versus TANYA ENERGY ENTERPRISES THROUGH ITS MANAGING PARTNER SHRI ALLURI LAKSHMI NARASIMHA VARMA

[2025] 9 S.C.R. 963 · 2025 INSC 1119

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Summary

The Supreme Court set aside High Court orders directing SBI to reconsider a defaulting borrower's application under its OTS 2020 Scheme. The application was not accompanied by the mandatory up-front deposit under clause 4(i), so it was not even liable to be processed. The Court held that, in appropriate cases and after notice to the affected party, a court may uphold an administrative rejection on an alternative ground that appears from the order's own narrative or the records, even if the ground stated is untenable.

Issues

  1. Whether the High Court was justified in interfering with SBI's rejection of the borrower's application under the OTS 2020 Scheme and directing its reconsideration.
  2. Whether a borrower who is not excluded by the 'not eligible' clause of an OTS scheme is automatically entitled to have its application considered.
  3. Whether a court reviewing an administrative order may sustain it on a ground not stated in the order but appearing from the record, consistently with Mohinder Singh Gill and related decisions.
  4. Whether the Supreme Court could go beyond the limited question noted while issuing notice on the special leave petition.

Provisions considered

Held

Result

Appeal allowed; the Division Bench and Single Judge orders set aside. SBI is free to proceed in accordance with law to enforce the security interest; the respondent may submit a fresh OTS proposal outside the OTS 2020 Scheme, which SBI may decide as it deems fit. The judgment does not otherwise affect proceedings pending before the DRT.

Judgment PDF: Supreme Court of India, [2025] 9 S.C.R. 963.