JIBON KRISHNA MUKHERJEE & ANOTHER vs NEW BHEERBHUM COAL CO. LTD. & ANOTHER.

The Supreme Court upheld the High Court's decision that Section 21, Rule 89 of the Code of Civil Procedure does not apply to sales conducted by a receiver appointed by the court under Section 51. The Court clarified that since a receiver is not required to issue a proclamation of sale, the provisions requiring such a proclamation are inapplicable. Furthermore, the Court ruled that the judgment debtor's repeated defaults justified the High Court's refusal to exercise discretion under Section 151, affirming the confirmation of the sale by the receiver.