M/S BHARAT STEEL TUBES LTD ETC. vs IFCI LTD .

The Supreme Court upheld the Delhi High Court's ruling that the Industrial Finance Corporation of India Limited qualifies as a 'financial institution' under Section 4A(2) of the Companies Act, 1956, and Section 2(1)(m) of the SARFAESI Act, allowing it to enforce security interests. The Court clarified that the definition of 'public financial institution' includes entities established under specific Central Acts or controlled by the Central Government, and noted that the lack of 51% control by the government disqualified the corporation from this status. The judgment affirmed the High Court's decision to vacate the injunction against the enforcement of security interests by the IFCI.