High Court Article 226 Writs in Banking Matters: When Are Writs Maintainable Against SARFAESI Actions? Natural Justice & Absolute Arbitrariness

High Court Writ Jurisdiction (Article 226) in Banking & SARFAESI Matters: Overcoming Alternative Remedy Bar, Quashing Arbitrary Actions & Protecting Constitutional Rights

Published by: Sumanjari & Co. Advocates

Section 1: Executive Overview & Practical Reality

In the hierarchy of Indian judicial remedies, Article 226 of the Constitution of India stands as the supreme constitutional bulwark against executive tyranny, statutory overreach, and administrative arbitrariness. The High Courts are clothed with plenary extraordinary writ jurisdiction to issue prerogative writs of certiorari, mandamus, and prohibition to preserve the rule of law. However, in the domain of banking recovery and SARFAESI enforcement, Article 226 represents the most fiercely contested battleground between distressed borrowers and secured creditors. In Uttar Pradesh, before the High Court of Judicature at Allahabad—both at the Principal Seat in Prayagraj and the Lucknow Bench—hundreds of writ petitions are filed weekly by citizens facing imminent dispossession from their residential homes, commercial complexes, and industrial plants.

The foremost institutional hurdle confronting any borrower invoking writ jurisdiction against a bank is the formidable doctrine of "exhaustion of alternative statutory remedies." Bank panel advocates and Standing Counsel for the State routinely raise preliminary objections relying upon the Supreme Court's pronouncements in United Bank of India v. Satyawati Tondon and PHR Invent Educational Society v. UCO Bank. Lenders argue that the SARFAESI Act, 2002 and the RDB Act, 1993 provide complete, self-contained legislative codes with specialized tribunals (DRT and DRAT), and that High Courts should mechanically dismiss all writ petitions at the threshold under the self-imposed bar of alternative remedy.

However, the rule of alternative remedy is a rule of judicial discretion and policy, not a rule of constitutional jurisdiction. As authoritatively held by the Supreme Court of India in the landmark constitutional authority in Whirlpool Corporation v. Registrar of Trade Marks, the alternative remedy bar does not operate when: (1) fundamental rights are violated, (2) principles of natural justice are breached, or (3) the proceedings are wholly without jurisdiction or ultra vires the parent statute. Where a bank acts with patent illegality—such as seizing agricultural land explicitly exempt under Section 31(i), executing a Section 14 order passed by an unauthorized executive magistrate, failing to serve a mandatory Section 13(2) notice, or proceeding during administrative vacancies in the DRT—the High Court not only possesses the constitutional power, but the solemn judicial duty to intervene, quash arbitrary recovery actions, and protect personal liberty and property rights under Article 21 and Article 300A of the Constitution.

Section 2: Statutory & Regulatory Framework

The constitutional powers of the High Court and their relationship with specialized banking recovery statutes are defined under the following legal provisions:

• Article 226 of the Constitution of India (Power of High Courts to Issue Writs):"(1) Notwithstanding anything in Article 32, every High Court shall have powers, throughout the territories in relation to which it exercise jurisdiction, to issue to any person or authority, including in appropriate cases, any Government, within those territories directions, orders or writs, including writs in the nature of habeas corpus, mandamus, prohibition, quo warranto and certiorari, or any of them, for the enforcement of any of the rights conferred by Part III and for any other purpose."
• Section 17 & Section 34 of the SARFAESI Act, 2002:
• Section 17(1): Provides the statutory forum of the Debt Recovery Tribunal (DRT) for any person aggrieved by measures referred to in Section 13(4).
• Section 34 (Civil Court Bar): Bars the jurisdiction of civil courts in respect of any matter which a DRT or DRAT is empowered to determine. Crucial Constitutional Distinction: Section 34 bars civil courts; it does not and cannot bar the constitutional writ jurisdiction of the High Courts under Article 226, which is an inviolable basic structure of the Constitution.
• Section 31 of the SARFAESI Act, 2002 (Statutory Exemptions from Enforcement): Codifies explicit statutory exclusions where the SARFAESI Act does not apply:
• Section 31(i): Any security interest created in agricultural land. Enforcement against agricultural land is totally prohibited; any notice or seizure is void ab initio for complete want of jurisdiction.
• Section 31(h): Any security interest for securing repayment of any financial asset not exceeding one lakh rupees (Rs. 1,00,000/-).
• Section 31(j): Any case in which the amount due is less than twenty percent (20%) of the principal amount and interest thereon.
• Section 14 of the SARFAESI Act (District Magistrate Executive Jurisdiction): A purely statutory administrative power vested strictly in the Chief Metropolitan Magistrate (CMM) or District Magistrate (DM). Section 14 orders passed by unauthorized sub-divisional magistrates without statutory state government delegation are coram non judice and amenable to quashing under Article 226.

Section 3: Landmark Judicial Precedents

The jurisdictional jurisprudence governing High Court writ intervention in banking matters has been delineated by the Supreme Court of India:

• Whirlpool Corporation v. Registrar of Trade Marks, Mumbai & Ors. (1998) 8 SCC 1: The foundational constitutional locus classicus governing the maintainability of writ petitions despite statutory remedies. The Supreme Court laid down:"The power to issue prerogative writs under Article 226 of the Constitution is plenary in nature and is not limited by any other provision of the Constitution... The High Court having regard to the facts of the case has a discretion to entertain or not to entertain a writ petition. But the alternative remedy has been consistently held by this Court not to operate as a bar in at least three contingencies, namely: (1) where the writ petition has been filed for the enforcement of any of the Fundamental Rights; (2) where there has been a violation of the principles of natural justice; and (3) where the order or proceedings are wholly without jurisdiction or the vires of an Act is challenged."
• United Bank of India v. Satyawati Tondon & Ors. (2010) 8 SCC 110: The Supreme Court's warning on alternative remedies in commercial matters:"It is true that the rule of exhaustion of alternative remedy is a rule of discretion and not one of jurisdiction, but it has to be kept in mind that this Court has frequently observed that where an effective and efficacious statutory remedy is available, the High Court should be extremely slow in entertaining a petition under Article 226... In matters relating to the recovery of loans and taxes, the High Courts should relegate the parties to the statutory remedies available under the RDB Act and SARFAESI Act."
• Harshad Govardhan Sondagar v. International Assets Reconstruction Co. Ltd. (2014) 6 SCC 1: The Supreme Court established that where a lawful tenant or third-party occupant's rights are threatened with extra-judicial summary eviction under Section 14, and the DRT lacks the power to restore tenancy possession prior to dispossession, a writ petition under Article 226 is fully maintainable to protect constitutional and statutory rights.
• PHR Invent Educational Society v. UCO Bank & Ors. (2024) 4 SCC 344: The Supreme Court reaffirmed Satyawati Tondon while reiterating that the High Court may interfere under Article 226 in banking matters only in exceptional, extraordinary circumstances where the action of the bank is palpably arbitrary, perverse, or devoid of statutory jurisdiction.
• Ram Kishun & Ors. v. State of U.P. & Ors. (2012) 11 SCC 511: The Supreme Court held that the right to property under Article 300A is a constitutional human right. In recovering public dues, the State and banking instrumentalities cannot act as private usurers; forced sale must strictly comply with mandatory statutory procedures, and surplus properties cannot be auctioned when sale of a portion suffices to clear the debt.
• K. Sreedhar v. Raus Constructions Pvt. Ltd. (2023) 5 SCC 526: Reaffirmed that agricultural land cannot be subjected to SARFAESI proceedings under Section 31(i). However, whether land is agricultural is determined by actual cultivation and revenue records, not mere nominal description.

Section 4: Stage-by-Stage Procedural Roadmap

To successfully invoke Article 226 before the Allahabad High Court (Lucknow Bench or Prayagraj) and defeat the Satyawati Tondon preliminary objection, counsel must execute a disciplined protocol:

• Step 1: Establishing the Strict Whirlpool Gateway Exception (Pre-Filing Audit):
• Before drafting, rigorously identify which of the three Whirlpool exceptions applies:
• Patent Lack of Jurisdiction: The asset is agricultural land under Section 31(i); the loan is under Rs. 1 Lakh under 31(h); or the Section 14 order was signed by an unauthorized officer.
• Gross Natural Justice Breach: The bank never served the mandatory Section 13(2) demand notice, or completely ignored the borrower's Section 13(3A) objection without communicating reasons.
• Absence / Vacancy of Statutory Forum: The DRT Lucknow / Allahabad is non-functional due to vacancy of the Presiding Officer or urgent court vacations, leaving the citizen with no immediate forum to prevent demolition or physical eviction.
• Step 2: Drafting the High Court Writ Petition (Civil Misc.):
• Frame the petition strictly under Article 226 of the Constitution of India, naming the Authorized Officer, the Bank, the District Magistrate, and the State of U.P. as respondents.
• Explicitly dedicate a prominent preliminary section titled "Maintainability of Writ Petition & Exceptions to Alternative Statutory Remedy", citing Whirlpool Corporation (1998) 8 SCC 1 and Harshad Govardhan Sondagar (2014) 6 SCC 1. Explain why relegating the petitioner to the DRT would cause immediate, irreparable loss of shelter under Article 21.
• Annex certified copies of revenue records (Khatauni) proving agricultural status, or postal tracking slips showing non-service of notices.
• Step 3: Tendering an Upfront Bona Fide Deposit (The Equity Factor):
• High Courts are courts of equity. To demonstrate pristine bona fides and dismantle the bank's accusation of "chronic defaulter," include a specific undertaking in the writ petition offering to deposit a reasonable upfront amount (e.g., 10% to 15% of the undisputed principal) within two weeks.
• Step 4: Urgent Listing, Mentioning & Overcoming Preliminary Objections:
• File the writ petition through e-filing and submit hard copies before the Reporting Section of the Allahabad High Court.
• Mention the matter before the designated Division Bench / Single Bench exercising commercial writ jurisdiction for urgent listing.
• At the preliminary hearing, aggressively address the maintainability hurdle before the bank can argue merits: prove that the bank's action is coram non judice, taking it completely outside the realm of Section 17 DRT proceedings.
• Step 5: Securing Interim Protection & Directing Objective Resolution:
• Obtain an interim stay restraining the District Magistrate and bank from executing physical dispossession or proceeding with the e-auction.
• Where appropriate, seek a writ of mandamus directing the bank to decide the petitioner's pending One-Time Settlement (OTS) proposal under its board-approved policy within a stipulated timeframe, maintaining status quo in the interim.

Section 5: Tactical Offenses, Defenses & Critical Pitfalls to Avoid

Litigating banking matters under Article 226 requires navigating sharp procedural boundaries:

• Tactical Offenses:
• The Section 31(i) Agricultural Land Knockout: If the mortgaged asset is recorded as agricultural land in the revenue records (Khatauni) and is actively cultivated, the bank has zero subject-matter jurisdiction under Section 31(i). The High Court will quash the Section 13(2) notice and Section 14 order in limine, as the DRT cannot cure a total absence of statutory jurisdiction.
• The Non-Functional DRT Doctrine: When the office of the Presiding Officer at DRT Lucknow or DRT Allahabad falls vacant, or during sudden judicial closures, file an urgent writ before the Allahabad High Court pleading "illusory statutory remedy." The High Court routinely entertains the writ to grant interim protection until the tribunal resumes functional operations.
• Enforcing Article 14 on Public Sector Banks: If a nationalized bank arbitrarily rejects an OTS proposal that strictly complies with its published, non-discretionary policy while granting haircuts to politically favored borrowers, invoke Article 14. The High Court will issue a mandamus under the Sardar Associates doctrine directing objective re-consideration.
• Creditor Tactics to Anticipate: Bank counsel will wave Satyawati Tondon and Celir LLP, aggressively shouting "alternative remedy before DRT." Counter this by immediately citing Whirlpool and demonstrating that the alternative remedy rule does not apply to jurisdictional nullities or fundamental rights violations under Article 21.
• Critical Pitfalls to Avoid:
• Suppressing the Filing of an SA before the DRT: Never file a writ petition while concealing that a Securitisation Application (SA) is already pending before the DRT. Doing so constitutes fraudulent "forum shopping." When the bank exposes this, the High Court will dismiss the writ with exemplary punitive costs (often Rs. 50,000/- to Rs. 1,00,000/-) and vacate all interim stays.
• Filing Writs Solely to Seek Loan Restructuring: Approaching the High Court merely asking for "extension of time to pay" or "easy installments" without challenging any illegal statutory notice is fatal. High Courts are not loan-restructuring agencies; such petitions are dismissed within two minutes.
• Delaying Until the Auction Purchaser Gets Possession: Once an e-auction is concluded and the sale certificate is registered in favor of a third-party purchaser under Celir LLP, High Courts will almost never interfere under Article 226. File the writ petition before the hammer falls.

Section 6: Ready-to-Use Court Drafting Template

Below is an unabridged, practical model legal pleading specifically drafted as a Civil Miscellaneous Writ Petition under Article 226 of the Constitution of India before the High Court of Judicature at Allahabad, Lucknow Bench, challenging an illegal Section 14 District Magistrate order and eviction notice targeting agricultural land and residential dwelling in violation of Section 31(i) of the SARFAESI Act, 2002.

IN THE HIGH COURT OF JUDICATURE AT ALLAHABAD

BENCH AT LUCKNOW

CIVIL MISCELLANEOUS WRIT PETITION NO. _______ OF 2026

(Under Article 226 of the Constitution of India)

DISTRICT: LUCKNOW

IN THE MATTER OF:

1. Shri Anil Kumar Verma, S/o Late Ram Swaroop Verma

Residing at: Village & Post Gosainganj, District Lucknow - 226501 ... PETITIONER NO. 1

2. Smt. Meera Verma, W/o Shri Anil Kumar Verma

Residing at: Village & Post Gosainganj, District Lucknow - 226501 ... PETITIONER NO. 2

VERSUS

1. State of Uttar Pradesh,

Through the Principal Secretary (Home), Government of UP, Civil Secretariat, Lucknow - 226001 ... RESPONDENT NO. 1

2. District Magistrate, Lucknow

Collectorate Compound, Qaiserbagh, Lucknow - 226001 ... RESPONDENT NO. 2

3. State Bank of India

Stressed Assets Management Branch (SAMB), 2nd Floor, Administrative Building, Hazratganj, Lucknow - 226001

Through its Authorized Officer ... RESPONDENT NO. 3

WRIT PETITION UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA FOR ISSUANCE OF A WRIT OF CERTIORARI QUASHING THE IMPUGNED SECTION 14 ORDER DATED 12TH AUGUST 2026 PASSED BY RESPONDENT NO. 2 AND THE NOTICE OF PHYSICAL DISPOSSESSION DATED 10TH SEPTEMBER 2026 ISSUED BY RESPONDENT NO. 3; AND FOR ISSUANCE OF A WRIT OF MANDAMUS COMMANDING THE RESPONDENTS NOT TO DISPOSSESS THE PETITIONERS FROM THEIR AGRICULTURAL LAND AND DWELLING HOUSE.

TO,

THE HON'BLE THE CHIEF JUSTICE AND HIS COMPANION JUDGES OF THE HON'BLE HIGH COURT OF JUDICATURE AT ALLAHABAD

THE HUMBLE PETITION OF THE PETITIONERS ABOVENAMED:

MOST RESPECTFULLY SHOWETH:

1. That the Petitioners are law-abiding citizens of India residing at Village Gosainganj, Lucknow, and are invoking the extraordinary constitutional writ jurisdiction of this Hon'ble Court to protect their fundamental rights guaranteed under Articles 14, 19, and 21, and constitutional property rights under Article 300A of the Constitution of India.

2. MAINTAINABILITY OF WRIT PETITION & EXCEPTIONS TO ALTERNATIVE REMEDY:

(a) That the Petitioners are acutely cognizant of the self-imposed rule of alternative statutory remedy under Section 17 of the SARFAESI Act, 2002 as enunciated in United Bank of India v. Satyawati Tondon (2010) 8 SCC 110.

(b) That the present Writ Petition is maintainable as an exceptional, extraordinary case falling squarely within the three cardinal exceptions authoritatively recognized by the Hon'ble Supreme Court of India in Whirlpool Corporation v. Registrar of Trade Marks (1998) 8 SCC 1 and Harshad Govardhan Sondagar v. International Assets Reconstruction Co. Ltd. (2014) 6 SCC 1, on the grounds that:

(i) COMPLETE ABSENCE OF JURISDICTION: The Respondent Bank has initiated SARFAESI enforcement against parcel of land measuring 1.45 Hectares at Khasra No. 342, Village Gosainganj, which is admittedly Agricultural Land in active agricultural cultivation, as recorded in the statutory revenue records (Khatauni). Under Section 31(i) of the SARFAESI Act, 2002, the provisions of the SARFAESI Act do not apply to agricultural land. The entire recovery proceedings are coram non judice and a complete nullity.

(ii) GROSS BREACH OF NATURAL JUSTICE: The Respondent Bank never served the mandatory Section 13(2) demand notice upon Petitioner No. 2, who is a joint co-owner of the property, having procured an ex-parte Section 14 order through fraudulent concealment from Respondent No. 2.

(iii) THREAT OF IMMEDIATE HOMELESSNESS UNDER ARTICLE 21: The local police and revenue authorities have issued a notice scheduling physical eviction and demolition for 28th September 2026. Relegating the Petitioners to the Debts Recovery Tribunal, which is currently non-functional due to the judicial vacancy of the Presiding Officer at DRT Lucknow, would render their constitutional rights illusory and result in immediate physical homelessness.

3. BRIEF FACTS OF THE CASE:

(a) That Petitioner No. 1 availed a Kisan Credit Card (KCC) and an Agricultural Term Loan aggregating Rs. 18,50,000/- in the year 2020 for agricultural farming and dairy development from Respondent No. 3 Bank.

(b) That to secure the said facility, Petitioner No. 1 created a simple agricultural mortgage over his ancestral agricultural bhumidhari land at Khasra No. 342, Gosainganj, Lucknow. A certified copy of the current statutory Revenue Khatauni for 1431-1436 Fasli showing the land as agricultural bhumidhari is annexed hereto as ANNEXURE P-1.

(c) That due to severe flooding in the Gomti river basin in 2024, the entire standing sugarcane and mustard crop of the Petitioners was destroyed, causing bona fide distress in servicing the account.

(d) That Respondent No. 3 Bank arbitrarily declared the account as NPA on 31st March 2025 and directly moved Respondent No. 2 (District Magistrate) under Section 14 SARFAESI without ever issuing or serving a Section 13(2) notice.

(e) That Respondent No. 2, without examining the mandatory 9-point affidavit and without verifying whether the asset was agricultural land, mechanically passed the impugned Order dated 12th August 2026 directing the Tehsildar, Mohanlalganj to take forceful physical possession with police assistance.

4. BONA FIDE DEPOSIT UNDERTAKING:

That to demonstrate their pristine bona fides and clean hands before this Hon'ble Court, the Petitioners hereby undertake on solemn affidavit to deposit a sum of Rs. 3,00,000/- (Rupees Three Lakhs Only) within two (2) weeks from today before Respondent No. 3 Bank, and pray for the settlement of their account under the Kisan Rin Samadhan Scheme.

5. PRAYER:

Wherefore, in light of the aforesaid facts, statutory provisions, and constitutional grounds, the Petitioners most respectfully pray that this Hon'ble Court may graciously be pleased to:

(a) Issue a Writ, Order, or Direction in the nature of CERTIORARI calling for the records and quashing the impugned Order dated 12th August 2026 passed by Respondent No. 2 (District Magistrate, Lucknow) under Section 14 of the SARFAESI Act, 2002 and the consequential Notice of Physical Dispossession dated 10th September 2026 issued by Respondent No. 3 Bank in respect of Khasra No. 342, Village Gosainganj, District Lucknow;

(b) Issue a Writ, Order, or Direction in the nature of MANDAMUS commanding Respondent Nos. 2 and 3 not to interfere with the peaceful physical possession, farming operations, and residential occupation of the Petitioners over Khasra No. 342, Village Gosainganj, District Lucknow;

(c) Issue a Writ of Mandamus directing Respondent No. 3 Bank to consider and decide the One-Time Settlement (OTS) proposal of the Petitioners in accordance with RBI Agricultural Debt Relief Guidelines within six weeks; and

(d) Pass such other and further orders as this Hon'ble Court may deem fit and proper in the circumstances of the case.

Dated: 24th September 2026

Place: Lucknow

PETITIONERS

THROUGH

SUMANJARI & CO. ADVOCATES

Counsel for the Petitioners

Chamber No. D-311, Block D, High Court of Judicature at Allahabad, Lucknow Bench

Section 7: Practical FAQs

• When can a borrower legitimately bypass the DRT and file a Writ Petition under Article 226 before the Allahabad High Court?Answer: A borrower can bypass the DRT and approach the High Court under Article 226 only when their case strictly satisfies one of the three exceptions established by the Supreme Court in Whirlpool Corporation v. Registrar of Trade Marks (1998) 8 SCC 1:
• Patent Lack of Jurisdiction: The bank initiates SARFAESI against agricultural land (exempt under Section 31(i)), a loan below Rs. 1 Lakh (Section 31(h)), or where a Section 14 order is passed by an unauthorized officer.
• Violation of Natural Justice: The bank fails to serve the mandatory Section 13(2) notice, or fails to communicate a reasoned reply to the borrower's Section 13(3A) objection.
• Enforcement of Fundamental Rights: Threat of unlawful, violent, or unconstitutional dispossession depriving the citizen of shelter under Article 21 without due process of law.
• Non-Functional Tribunal: When the Debt Recovery Tribunal is non-functional due to judicial vacancies or prolonged strikes, leaving the citizen with no immediate forum to seek interim protection.
• What should a borrower do if the DRT is non-functional due to a vacancy of the Presiding Officer and the bank is taking physical possession?Answer: When the DRT is non-functional due to a vacancy of the Presiding Officer, the statutory remedy under Section 17 becomes completely illusory. In such circumstances, the borrower must immediately approach the Allahabad High Court (Lucknow Bench or Prayagraj) under Article 226. The writ petition must specifically plead the factual vacancy at the DRT, annex notices of physical possession, and pray for interim protection. The High Court routinely entertains such writ petitions, grants an interim stay of physical eviction, and directs that the stay shall continue until the Presiding Officer assumes charge and hears the Section 17 application.
• Can the High Court quash a Section 14 District Magistrate order if the borrower was not heard prior to the order?Answer: The Supreme Court in NKGSB Co-op. Bank v. Subir Chakravarty (2022) 10 SCC 286 held that Section 14 is an administrative, executive assistance mechanism, and the District Magistrate is not required to conduct a full trial or issue an adjudicatory notice to the borrower. However, the DM is strictly required to verify the 9-point affidavit mandated by the 2013 amendment to Section 14. If the bank filed a false affidavit, if no Section 13(2) notice was ever served, if the property is exempt agricultural land, or if the order was signed by an unauthorized officer, the Section 14 order is ultra vires and the High Court will quash it under Article 226.
• How can an agriculturalist prevent the bank from auctioning their agricultural land under the SARFAESI Act?Answer: By invoking Section 31(i) of the SARFAESI Act, 2002. Section 31(i) contains an absolute statutory bar: "The provisions of this Act shall not apply to... any security interest created in agricultural land." If a bank issues a Section 13(2) demand or attempts to take possession of agricultural land, the landowner should immediately file a Writ Petition under Article 226 before the High Court. The petition must annex certified copies of the Revenue Khatauni proving that the land is recorded as agricultural bhumidhari and is under active cultivation. The High Court will issue a writ of certiorari quashing the SARFAESI notices for complete lack of subject-matter jurisdiction.
• Is filing a Writ Petition considered illegal "forum shopping" if the borrower has already filed a Section 17 SA before the DRT?Answer: Yes, if the borrower conceals the pending DRT application. If a borrower files a Section 17 Securitisation Application before the DRT, fails to obtain an interim stay, and then files a writ petition before the High Court concealing the DRT proceedings, it constitutes fraudulent "forum shopping." The High Court will immediately dismiss the writ petition with heavy costs. However, if the borrower openly discloses the pending DRT proceedings and approaches the High Court solely because the DRT is non-functional, or because the bank committed a sudden, independent jurisdictional illegality, the writ petition is maintainable for limited interim relief pending DRT adjudication.

Sumanjari & Co. Advocates

Rooted in Law. Rising with You. | Your Right, Our Resolve.

Chamber Office: Chamber No. D-311, Block D, Allahabad High Court, Lucknow Bench, Gomti Nagar, Lucknow, UP

Courts & Tribunals: Allahabad High Court (Lucknow Bench & Prayagraj) | UP RERA & UP REAT | Serving Noida, Ghaziabad & Lucknow

Key Contacts: Adv. Jitendra Tiwari (+91 82990 86204) | Adv. Aishwarya Pandey (+91 83024 71764)

Email: info.sumanjarirightsandremedies@gmail.com | Website: sumanjariadvocates.com

Disclaimer: For informational purposes only under Bar Council of India rules; does not constitute solicitation or legal advice.