M.D. FROZEN FOODS EXPORTS PVT. LTD. vs HERO FINCORP LTD.

The Supreme Court addressed the procedural complexities in the recovery of debts by financial institutions under the Recovery of Debts Due to Banks and Financial Institutions Act, 1993 (RDDB Act) and the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 (SARFAESI Act). The Court emphasized the need for a swift recovery process to support industrial development, affirming that the SARFAESI Act provides a framework for banks to recover dues efficiently. The Court upheld the applicability of the SARFAESI Act to Non-Banking Financial Companies (NBFCs) as specified under Section 2(m) and Section 31A of the Act, thereby reinforcing the legal provisions for asset securitization and recovery.