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Author: Simran Chaudhary, III year of B.A.,LL.B from Delhi Metropolitan Education, Noida, GGSIP University, New Delhi.


The financial sector has played a pivotal role in India's rapid economic development, but it has not been without its challenges. The government established “Debt Recovery Tribunals (DRTs)” in 1993 under the “Recovery of Debts Due to Banks and Financial Institutions Act (RDDBFI)”, which has provided a robust framework for banks to initiate speedy debt recovery proceedings. To address this issue, the government implemented the “Securitization and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 (SARFAESI)” to facilitate the prompt and effective retrieval of “non-performing assets (NPAs)” of banks and financial institutions. This article delves into the challenges faced by India's financial sector despite its crucial role in the country's economic growth. It focuses on the legal framework for debt recovery, including the establishment of DRTs and the enactment of SARFAESI, and evaluates their effectiveness in resolving non-performing assets. The article also discusses the issues and limitations of DRTs, such as legal delays and insufficient infrastructure. Finally, the article provides insights on potential measures to enhance the potency of legal framework and improve the recovery of stressed assets to support the continued growth of the financial sector in India.

KeywordsDebt Recovery Tribunal, RDDBFI Act 1993, SARFAESI Act 2002, NPA


India has long been considered a promising destination for green-field investment and competition due to its robust investment and competition laws, which have been in place for quite some time, giving it an edge over its developing counterparts. The financial sector has played a pivotal role in India's rapid economic development, but it has not been without its challenges. One significant issue that banks and financial institutions have faced is the recovery of loans they have extended to individual borrowers and business entities. This has led to a decline in loan disbursements as banks and financial institutions became more cautious in their lending practices. To address this problem, the government established Debt Recovery Tribunals (DRTs) in 1993 under the “Recovery of Debts Due to Banks and Financial Institutions Act (RDDBFI)”, which has provided a robust framework for banks to initiate speedy debt recovery proceedings.

“Debt Recovery Tribunals (DRTs)” have been pivotal in facilitating the prompt resolution of debt recovery cases and expediting recovery proceedings. With 39 DRTs and 5 Debt Recovery Appellate Tribunals (DRATs) currently functioning across the nation, the tribunals have played a crucial role in easing the burden on banks and financial institutions by enabling the timely recovery of loans. The swift adjudication of matters pertaining to debt recovery has significantly reduced the backlog of cases and ensured the efficient functioning of the overall recovery process.

One area where the legal framework has struggled to keep up is the enforcement of securities interests. To address this issue, the government implemented the “Securitization and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 (SARFAESI)” to enable efficient recovery of “non-performing assets (NPAs)” of banks and financial institutions. The primary objective of SARFAESI is to provide a robust legal framework for the speedy recovery of NPAs, which can be used as security for loans extended by banks and financial institutions.

Despite the action taken by the government, the challenges facing the financial sector remain significant. This research article seeks to analyse the existing legal framework concerning commercial transactions, DRT’s efficiency, functions and composition and will explore how it can be strengthened to better address the challenges facing the financial sector. Specifically, the article will examine the impact of DRTs and SARFAESI on loan recovery and identify areas where the legal framework can be improved to promote efficient debt recovery and protect the interests of all stakeholders involved.


A “Debt Recovery Tribunal (DRT)” is a specialized court or a quasi-legal institution in India that deals with cases related to the recovery of debts from defaulting borrowers. It was established under the “Recovery of Debts Due to Banks and Financial Institutions Act of 1993”. The principal role of DRTs is to enable the expeditious resolution of debt recovery cases by furnishing a specialized platform for the adjudication of such matters.

Debt Recovery Tribunals (DRTs) are vested with the authority to hear and adjudicate on cases pertaining to the recovery of debts that exceed a prescribed limit, which was raised to twenty lakh rupees in 2018. These Tribunals possess extensive jurisdiction to render orders that surpass the scope of the CPC, including the authority to entertain counterclaims, cross-suits, and permit set-offs. After hearing and evaluating the case, the DRT passes an order and grants a Recovery Certificate that declares the sum due from the borrower. The Recovery Certificate issued by the DRT is enforced by Recovery Officers through a process similar to the one used for the recovery of income tax.

There are currently 39 DRTs and 5 DRATs operating in India. It plays a vital role in facilitating the effective retrieval of debts owed to banks and financial institutions. The specialized forum provides a mechanism for creditors to expedite the recovery process by pursuing legal recourse in a dedicated forum, rather than relying on conventional legal channels., and in promoting a more efficient and effective debt recovery process in India.

Furthermore, every Debt Recovery Tribunal has two Recovery Officers, who are responsible for handling the allotted work as directed by the Presiding Officer. The tenure of a Recovery Officer is restricted to a maximum of five years or until they reach the age of sixty-five years, whichever comes first. Despite not being Judicial Officers, the orders issued by Recovery Officers carry significant legal weight and hold judicial importance and can be challenged before the Presiding Officer of the Tribunal.

In essence, the Recovery of Debts and Bankruptcy Act, 1993 ensures that each Debt Recovery Tribunal operates with a fair and impartial judiciary, with a Presiding Officer at the helm, supported by officers of various ranks, including Recovery Officers who hold significant responsibility in the judicial process.


  • Pre DRT-Resolution Process –

In the past, banks and financial institutions faced the daunting task of initiating a civil lawsuit to recover funds from their borrowers. The process was lengthy and complex, being governed by the provisions of the Civil Procedure Code (CPC), 1908. Recognizing the strain that the backlog of cases was putting on the courts, in 1981, a committee led by Mr. T. Tiwari was set up to recommend reforms.

The committee recognized the necessity of implementing steps to accelerate the resolution of cases pertaining to the retrieval of outstanding payments owed to banks and financial establishments. It recommended various options, including the establishment of quasi-judicial bodies dedicated to handling recovery matters. However, it took nearly a decade for such bodies to be implemented, coinciding with the liberalization of the Indian financial market and economy.

The arduous process of recovering funds through civil court litigation led to the formation of a committee to suggest reforms, which ultimately recommended the creation of specialized quasi-judicial bodies for recovery matters. Despite the delay in implementing this suggestion, such bodies were eventually established as part of India's economic liberalisation.

  • The RDDBFI Act, 1993 –

In 1991, the Narasimham Committee expressed support for the recommendations put forth by the Tiwari Committee and advocated for the creation of specialized tribunals to handle cases related to debt recovery. This led to the enactment of the “Recovery of Debts Due to Banks and Financial Institutions Act (RDDBFI)” in 1993.

Under this legislation, two types of agencies were established, namely the “Debt Recovery Tribunals (DRTs)” and the “Debt Recovery Appellate Tribunals (DRATs)”. These organizations were bestowed with extraordinary authority to adjudicate issues concerning the retrieval of debts owed to banks and financial institutions. The first DRT commenced its operations in Kolkata on April 27, 1994, marking a significant step forward in streamlining the process of debt recovery.


In 1995, the High Court of Delhi deemed the Recovery of Debts Due to Banks and Financial Institutions Act (RDDBFI) to be unconstitutional, citing its potential to compromise the autonomy of the judiciary. Nevertheless, the Supreme Court allowed for the continuance of Debt Recovery Tribunals (DRTs) subject to necessary modifications being made to the RDDBFI. Subsequently, the government introduced amendments to the RDDBFI in 2000 and 2002, which the Supreme Court acknowledged as being in accordance with the Constitution. Thus, at present, the functioning of DRTs is considered to be constitutional.


“The Recovery of Debts and Bankruptcy Act, 1993” stipulates in Section 4 the structure of DRTs. These tribunals are led by a Presiding Officer, who is typically a District and Sessions Judge, and holds the sole power to hear and render any judicial orders. The Presiding Officer is supported by a team of officers with diverse ranks, who are not necessarily mandated to have legal expertise.


The RDDBFI Act's Section 17 confers the authority to receive applications from banks and financial institutions aiming to recuperate debts owed to them upon the DRT. It is essential to understand that the DRT's jurisdiction is limited to the cases mentioned under this section of the Act, and it cannot make decisions on other matters such as property succession rights or issuance of receipts.

It is important to mention that the verdict in the case of L Chandra Kumar determined that tribunals serve as an adjunct to High Courts rather than a substitute for them. Section 18 of the Act stipulates that other courts are not allowed to intervene in debt-related matters except for the High Court and the Supreme Court, which have the constitutional mandate to exercise such authority under Article 226 and 227. The DRAT, as an appellate tribunal, has the power to hear appeals against orders issued by the DRT under the Act. Any appeal against the DRAT's order can only be filed with the High Court or the Supreme Court.


Debt Recovery Tribunals (DRTs) are vested with the authority to handle debt recovery cases exceeding the value of Rs. 10 lakhs. This amount limit was increased to Rs. 20 lakhs in the year 2018. In instances where the amount in question is lower than the prescribed limit, the banks and financial institutions involved must seek relief from the civil court in compliance with the regulations of the Civil Procedure Code (CPC). However, the “Recovery of Debts Due to Banks and Financial Institutions Act (RDDBFI)” allows for the Central government to direct certain cases exceeding Rs. 1 lakh to be taken up by the DRTs. Additionally, the “Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act (SARFAESI)” specifies certain categories of cases involving different amounts that can be adjudicated by the DRTs.


  • DRTs have the power to call and examine any person under oath;

  • They can demand the disclosure and presentation of documents;

  • Affidavits can be used as evidence in DRT proceedings;

  • DRTs can issue commissions to examine witnesses or documents;

  • The tribunal has the power to review its own decisions;

  • DRTs can dismiss an application if the defendant fails to respond or decide the matter in their absence;

  • They can also issue interim orders, such as injunctions or attachments, to prevent the defendant from dealing with the property or asset in question without the tribunal's permission and

  • DRTs possess the power to order the debtor to furnish suitable collateral as assurance for the repayment of the debt.


The Narasimham and Andhyarujina Committees were established by the Central Government to evaluate reforms in the banking sector and recommend modifications to the legal framework. One of their recommendations was to enact a new law for securitization, granting banks and financial institutions the authority to seize assets and dispose of them without the involvement of a court. This led to the “Securitization and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002”, which permits recovery of dues exceeding one lakh rupees through the enforcement of secured assets without court or tribunal intervention.


The legislation pertains to the following matters –

  • Registering and regulating “Asset Reconstruction Companies (ARCs)” by the “Reserve Bank of India (RBI)”.

  • Enabling Banks and Financial Institutions to securitize their Financial Assets, whether or not they are backed by underlying securities.

  • Promoting the effortless transfer of financial assets by ARCs by issuing debentures, bonds, or other securities.

  • Granting ARCs, the authority to generate resources by selling security receipts to eligible purchasers.

  • Assisting in the restructuring of financial assets acquired through enforcement of securities or change in management, or other authorized powers granted to financial institutions.

  • Broadening the scope of "Security Interest" to include all forms of collateral, such as liens or mortgages on real estate, pledged to secure repayment of financial aid from Banks or Financial Institutions.

The enactment of the Securitization Act aimed to assist banks and financial institutions in recovering their overdue payments through a non-adjudicatory mechanism.

  • The Code of Civil Procedure was deemed insufficient for debt recovery, hence the “Recovery of Debts due to Banks and Financial Institutions Act, 1993” was introduced. However, experience showed that it was not effective, resulting in the passing of the SARFAESI Act. This legislation empowers Banks and Financial Institutions to realize their long-term assets, address liquidity issues, and enhance recovery efforts by assuming control of securities and liquidating them to decrease “Non-Performing Assets”.


The Supreme Court has expressed that the Act confers an advantage to one party over the other, yet it cannot be considered unconstitutional. The rationale behind this legislation is to accelerate the recovery of loans that have been classified as Non-Performing Assets (NPA), facilitate easier access to capital, liquidity, and resources, and foster economic growth and the well-being of the populace, all of which are in the public interest. This is accomplished by empowering banks and financial institutions to seize and liquidate assets offered as collateral to reduce their NPA and enhance their financial position.


A “Non-Performing Asset (NPA)” refers to an account or asset of a borrower which has been identified as a substandard, doubtful or loss asset by a bank or financial institution, as per the directives provided by either the regulating authority or the “Reserve Bank of India”. Such classification allows for the efficient monitoring and management of the borrower's financial obligations, and ensures that the bank or financial institution can take necessary actions to recover the dues and minimize losses. Before classifying an asset as NPA, banks are required to follow a specific procedure based on the evidence of recovery and cannot do so merely due to a temporary deficiency


Application Submission – One can file an appeal or request with the Debt Recovery Tribunal (DRT) either directly or by following the SARFAESI process.

  • The Application Route –

To commence the process of debt recovery using this approach, the lender must submit an application to the DRT and make the necessary payment. The selection of the appropriate DRT is critical to the success of this process. Currently, there are 39 DRTs located in 22 different regions. Section 19 of the RDDBFI Act outlines the criteria for selecting a DRT for filing an application. A bank or financial institution may approach a DRT that has authority over the area in which the financial institution conducts business. In addition, the lender may file an application with a specific DRT if the cause of action, either in whole or in part, falls within its jurisdiction. However, the selection of the appropriate DRT may be a complex process, and careful consideration must be given to this factor.

  • SARFAESI Route –

Under the SARFAESI Act, an application can also be made to the DRT for the recovery of dues by the secured creditor. The Act recognizes the necessity to reinforce the rights of secured creditors and provides a procedure for them in which they can retrieve their outstanding payments without the need for external intervention or legal proceedings.

Upon the classification of a loan as a Non-Performing Asset (NPA) by the secured creditor, a notice is dispatched to the borrower in accordance with Section 13(2) of the SARFAESI Act, specifying the amount that needs to be repaid in full within 60 days. Should the borrower fail to meet the repayment obligations, the secured creditor may exercise the rights conferred under Section 13(4) of the Act, which includes the right to take possession of the secured asset, lease or transfer it, or appoint a person to manage the asset.

In situations where the collateral asset fails to satisfy the borrower's obligations to the creditors, the latter may approach the DRT for the recovery of the remaining dues. In such cases, the borrower retains the right to challenge any action initiated by the creditor under Section 13(4) by appealing under Section 17 of the SARFAESI Act. It is essential to note that the SARFAESI Act empowers creditors to take possession of and sell the secured assets of defaulters without the intervention of courts or tribunals, subject to certain conditions. However, borrowers may seek legal remedies if they feel that their rights have been violated during this process.


Comprehending the meaning of laws can be a complex and demanding undertaking, especially when different legislations clash in their ambit and scope, giving rise to unforeseen issues. Such situations may arise when seemingly supplementary legislations actually address distinct issues.

One such situation involves defaulters and the conflicting statutes of the “Recovery of Debts Due to Banks and Financial Institutions Act, 1993” and the “Securitization and Reconstruction of Financial Assets and Enforcement of Securities Interest Act, 2002.”

Upon a closer analysis of SARFAESI, it becomes clear that its primary focus lies on the regulation of the securitization and reconstruction of financial assets, as well as the enforcement of security interest. Conversely, the RDDB&FI Act lays down provisions for the creation of Tribunals that are designed to facilitate the prompt adjudication and recovery of debts owed to banks and other financial institutions. Furthermore, SARFAESI is limited in its scope to secured creditors, while RDDB&FI extends to all creditors, regardless of whether their claims are secured or unsecured.

The RDDB&FI and SARFAESI Acts offer unique solutions, with RDDB&FI serving as a legal decision-making tool and SARFAESI serving as a means of executing legal decisions. As such, these laws provide separate and distinct approaches for handling debt recovery


The DRTs are facing a plethora of problems which is hampering their effectiveness. The overburdening of some Tribunals in major cities has resulted in a low success rate. In recent times, DRTs have been grappling with several ancillary issues such as state and workmen dues, which are beyond their core mandate of resolving loan recovery disputes. Moreover, borrowers have adopted dilatory tactics by initiating claims against lenders in civil courts, resulting in further delays in the recovery process. Some courts have also interpreted the provisions of the Act in favour of the borrowers, invoking the principles of natural justice to safeguard their interests. Furthermore, DRTs are not equipped to handle the intricacies of legal issues and evolving methods of fraud. With only a limited number of DRTs established across the country, they are unable to effectively deal with the substantial volume of cases that arise. Financial institutions have faced difficulties in recovering loans and enforcing securities. To address this issue, the Debts Recovery Tribunal oversees the “Recovery of Debts Due to Banks and Financial Institutions Act” and the “Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interests Act”. Despite dealing with complex commercial laws, the Tribunal has gained expertise over time with the help of judgments from higher courts. The most effective methods of dispute resolution are out-of-court settlements, withdrawals, and compromises, as district and high court cases often suffer from long delays. While legal scholars attribute the inefficiency of the court system to various factors, it is widely recognized that loopholes play a significant role.


The significance of expeditious debt recovery cannot be overstated for a multitude of reasons. Firstly, since banks' funds are intended for public use and commercial ventures that significantly impact people, a delay in recovering trapped money can lead to difficulties in financing projects, which could previously be funded. Secondly, NPAs (Non-Performing Assets) negatively impact the bank's profitability, making debt recovery essential for its smooth functioning. Thirdly, a financial crisis in the bank could have serious repercussions on all stakeholders, including employees, management, and investors. Fourthly, a large number of NPAs can harm the bank's reputation and discourage investors. Additionally, if the NPA is not recovered quickly, it can decrease the bank's return on investment, when debts are not recovered promptly, it can result in financial losses for banks and financial institutions, as the interest on capital gets blocked, and this can impact their profitability.


The Recovery of Debts and Bankruptcy Laws have assigned the responsibility of debt recovery and related cases to the DRTs and DRATs, which has led to exclusion of the courts' jurisdiction in such matters. However, civil courts still have a role to play in resolving certain issues such as KYC norms, issuance of receipts and succession, as the powers of DRTs are limited to Section 17. This has resulted in delays in the process of settlement.

The establishment of DRTs and DRATs was intended to alleviate the load on the courts and facilitate an efficient resolution process. However, the problem seems to have only shifted to these tribunals. According to the “Deshpande Committee Report”, the recommended caseload that a DRT is required to manage at a given time was 30, but in major cities, even in the beginning stages, this number was as high as 4000.

DRTs have a success rate of less than 25%, which is worrisome. The caseload of DRTs has experienced a surge, mainly because of peripheral concerns like workmen dues, state dues, and claims linked to unsecured assets. Furthermore, borrowers frequently employ delaying tactics by filing claims against lenders in civil courts. The landmark case of "Union of India & Anr v Delhi High Court Bar Association & Ors." had a significant impact on debt recovery. The Delhi High Court had declared the RDDB & FI Act 1993 as unconstitutional, but the Supreme Court found the Act to be valid, though some modifications were necessary.

Although the lawmakers aimed to provide an advantageous approach to creditors, certain provisions have been interpreted by the courts to safeguard debtors. Despite the fact that the proceedings are summary in nature and the CPC does not apply, the courts have emphasized that principles of natural justice cannot be disregarded. For instance, in the case of “Mathew Varghese v. M. Amritha Kumar”, the court held that rules 8 and 9 of SARFAESI Act make it mandatory to give notice to the defaulter before the sale of a secured asset.

The issue of frustration regarding the jurisdiction of DRTs has surfaced due to litigants filing suits in civil courts, leading to the transfer of cases. Despite the Supreme Court's pronouncement that consent is not a prerequisite for such transfers, subsequent cases have provided little clarity on the issue. One of the primary concerns is that DRTs may not have the necessary tools to address complicated legal matters, such as those related to fraud and misrepresentation, due to their limited summary proceedings.


In order to improve debt management, significant changes have been introduced such as the establishment of Credit Information Bureaus under the “Credit Information Bureau Act, 2005”. The creditworthiness and credit rating information of borrowers is crucial in any debt industry, and the emergence of numerous credit rating agencies has made this information more accessible. The practice of granting credit based on credit ratings is gaining popularity.

The government has implemented various measures to tackle the problem of pending cases in the Tribunals and to improve the current framework. One of the significant changes is the amendment made to the RDDBFI Act of 1993 in 2016. The introduction of the Insolvency and Bankruptcy Code has been a significant measure that has granted DRTs with more power and jurisdiction to handle bankruptcy cases related to individuals and unlimited liability entities.

The Insolvency and Bankruptcy Code has vested the DRTs with enhanced powers to deal with insolvency cases of natural persons and unlimited liability entities. Furthermore, the central government has been authorized to establish standardized procedural guidelines for the effective functioning of the “Debts Recovery Tribunals and Appellate Tribunals”. The RDBBFI Act has undergone an amendment in 2016, which has increased the retirement age of DRT's Presiding Officers from 62 to 65 years, and Appellate Tribunal's Chairpersons from 65 to 67 years to allow them additional time to resolve pending cases.

The RDBBFI Act 1993 has been amended to allow the reappointment of Presiding Officers and Chairpersons to their positions, while also permitting banks to file cases in DRTs that have jurisdiction over the area where the bank office is located for pending debts. This is in contrast to filing cases in DRTs that have jurisdiction over the place of residence or business of the respondent. The amendment is expected to streamline the debt recovery process and ensure more effective adjudication of cases.

The aim is to reduce delays in debt recovery by increasing the cost borne by borrowers who delay the recovery process through prolonged interests and legal procedures. As per the amendment, under the DRT Act, borrowers are now mandated to deposit a minimum of 25% of the outstanding amount with the Debt Recovery Appellate Tribunal (DRAT) to obtain an interest, which was previously a requirement only under the SARFAESI Act.


Financial institutions and banks aim to achieve a faster and more efficient method of recovering debts. Despite the significant potential of “Debt Recovery Tribunals (DRTs)” To expedite the process of reclaiming of outstanding loans, there are numerous obstacles that impede their optimal functioning. One of the main challenges is the absence of legal expertise among the recovery officers designated by the Indian government to assist managing officers. Additionally, the inconsistency in the procedures implemented across various DRTs hampers the standardization of the debt recovery process. Moreover, there are substantial delays in the resolution of cases, which are expected to conclude within six months, but frequently extend for several years. These hurdles undermine the efficacy of DRTs and impede their ability to efficiently resolve the issue of unpaid loans.

There is an urgent need to introduce greater accountability for the “Debt Recovery Tribunals”. The suboptimal performance of “Debt Recovery Tribunals (DRTs)” can be attributed to several factors. Firstly, recovery officers appointed by the Indian government to support presiding officers lack judicial training, impeding their ability to carry out their duties effectively. Secondly, DRTs operate with inconsistent procedures, which result in uneven outcomes across different jurisdictions. Finally, the duration of proceedings is significantly prolonged beyond the recommended six-month period, with many cases dragging on for more than two years. These impediments compromise the efficacy of DRTs and compromise their ability to provide an expeditious resolution to the problem of unpaid loans.

The availability of Debt Recovery Tribunals (DRTs) and Debt Recovery Appellate Tribunals (DRATs) to challenge judgments is severely constrained due to their limited numbers. Despite having 39 DRTs, the country only has five Debt Recovery Appellate Tribunals. It is necessary to establish more DRTs to deal with the rising number of cases. In addition, a feedback mechanism should be implemented to allow people associated with DRTs to identify areas for improvement.

The legal system of our country is slow and inadequate, which hinders the process of resolving disputes. To expedite the process of recovery, a fixed time period should be established for all transfers, and the acceptance of assets could be accelerated by setting up special courts to deal with such recoveries.

The Reserve Bank of India (RBI) has expressed apprehension regarding the efficacy of Debt Recovery Tribunals (DRTs). If banks are unable to recover their loans, they will not be willing to lend at low rates. Therefore, it is crucial to enhance the effectiveness of debt recovery councils by minimizing the frequency of adjournments and orders.



Books –

  1. Bhattacharya, D. K. (2011). Basics of Banking and Finance (Second ed.). Mumbai, Maharashtra, India: Himalaya Publishing House.

  2. Chandra, P. (2006). Financial Management. New Delhi: The Tata McGraw-Hill Companies.

  3. I.M., P. (2004). Financial Management. New Delhi: Vikas Publishing House.

  4. A. Adhvani, Investment and Securities Market in India, Himalaya Publishing House, 2001, (9th Edition).

Acts –

  1. Recovery of Debts and Bankruptcy Act, 1993.

  2. The Securitization and Reconstruction of Financial Assets and Enforcement of Securities Interest (SARFAESI), Act, 2002.

Website –

  1. Deolalkar, G.H. The Indian Banking Sector: On the Road to Progress. Available at:

  2. Rakesh Mohan and Partha Ray, Indian Financial Sector: Structure, Trends and Turns, International Monetary Fund,

  3. Nidhi Singh and Ritika Singh, ‘Debt Recovery Tribunal: An Analysis’, Journal of Legal Studies and Research (JLSR); Volume 2 Issue 3.



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