Full Judgment Text
$~13
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ W.P.(C) 10690/2021 & CM APPL. 32959/2021
MORGAN ASIA LIMITED ...Petitioner
Through: Mr. J.M. Kalia, Mr. Dhruv Kalia and
Mr. Siddharth Shukla, Advocates.
versus
RESERVE BANK OF INDIA & ANR. ... Respondents
Through: Mr. Ramesh Babu with Mr. Manish
Singh, Ms. Tanya Choudhary and
Ms. Jagriti Bharti Advocates for
Respondent-1/RBI.
Mr. Ripu Daman Bhardwaj, CGSC
for UOI.
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%
Date of Decision: 20 August, 2024
CORAM:
HON'BLE THE ACTING CHIEF JUSTICE
HON'BLE MR. JUSTICE TUSHAR RAO GEDELA
JUDGMENT
TUSHAR RAO GEDELA, J :
1. Present petition has been preferred by the petitioner, inter alia,
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seeking declaration of notification no. RBI/2014-15/299 dated 10
November, 2014, bearing no. DNBR(PD) CC No. 002/03.10.001/2014-15
issued by the respondent/Reserve Bank of India (for short “RBI” ) as ultra
vires of section 45-IA (3) of Reserve Bank of India Act, 1934 (for short
“RBI Act” ) and also a declaration that proviso clause attached to section
45-IA(6) as ultra vires the Constitution, being discriminatory and violative
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of Article 14 of the Constitution of India apart from other provisions of the
RBI Act. Simultaneously, the petitioner also seeks to set aside order of
cancellation of the Certificate of Registration (for short “CoR” ) issued by
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the respondent bearing no.1402/CAMS/05.08.000/2018-19 dated 12
September, 2018 along with the corresponding order of the Adjudicating
Authority of the respondent, and in consequence thereof, to set aside the
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order of the Appellate Authority dated 15 April, 2020.
2. The petitioner company is a non-deposit accepting Non-Banking
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Financial Company (for short “NBFC” ), duly incorporated on 18
September, 1981, under the Companies Act, 1956. The petitioner was
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granted a CoR bearing No.14.00178 dated 3 March, 1998, by the RBI
under the provisions of section 45-IA of the RBI Act, to carry on the
business of a Non-Banking Financial Institution (for short “NBFI” ) subject
to fulfilling the requirements under Chapter III-B of the RBI Act and
complying with the directions, regulations, including prudential norms
issued by the respondent/RBI from time to time as also the terms and
conditions under which the said CoR was issued to it.
3. Provisions of section 45-IA(1)(b) of the RBI Act stipulate that no
NBFC can carry on the business of a NBFI without having a Net Owned
Fund (for short “NOF” ) of Rs.200.00 lakhs or such other amount, not
exceeding Rs.200.00 lakhs, as the RBI may, by notification in the Official
Gazette, specify. In terms of the notification issued by RBI being
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No.DNBS.132/CG(VSNM)-99 dated 20 April, 1999, the requirement of
minimum NOF for new companies applying for the grant of CoR to
commence business of an NBFC was raised from Rs.25.00 lakhs to
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Rs.200.00 lakhs. However, the minimum NOF for companies that were
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already in existence before 21 April, 1999, was retained at Rs.25.00 lakhs.
Subsequently, respondent/RBI vide circular RBI/2014-15/520 DNBR (PD)
CC.No.024 /03.10.001/2014-15 on Revised Regulatory Framework for
NBFCs read with notification No.DNBR.007/CGM(CDS)-2015, both dated
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27 March, 2015, specified Rs.200.00 lakhs as the NOF required for all
NBFCs to commence or carry on the business of NBFIs. However, the
NBFCs holding a CoR issued by the RBI and having NOF less than
Rs.200.00 lakhs were permitted to carry on the business of NBFIs provided
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such companies achieve the NOF of Rs.200.00 lakhs before 1 April, 2017.
As per para No.4.3 of the Revised Regulatory Framework for NBFC
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RBI/2014-15/299 DNBR (PD) CC. No.002/03.10.001/2014-15 dated 10
November, 2014, the NBFCs failing to achieve the prescribed ceiling
within the stipulated time period shall not be eligible to hold the CoR as
NBFCs and the respondent/RBI would initiate the process for cancellation
of CoR against such NBFCs.
4. Though the petitioner was holding a CoR issued by respondent/RBI
on the date of issuance of the aforementioned directions, yet it failed to
comply with the requirement of NOF of Rs.200.00 lakhs by the end of
March, 2017 and was alleged to be in violation of the directions issued by
RBI. Accordingly, the petitioner was called upon vide letter
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No.DNBS.ND.No.4116/CMS/05.08.000/2017-18 dated 25 May, 2018,
issued by respondent/RBI, to show cause, within fifteen (15) days of the
receipt of the said notice, as to why the CoR issued to it should not be
cancelled under section 45-IA(6) of the RBI Act. The petitioner replied to
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the said Show Cause Notice (for short “SCN” ) vide letter dated 09 June,
2018. Since, the said reply was not found to be satisfactory, the
Adjudicating Authority of the respondent/RBI had cancelled the CoR of the
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petitioner vide order dated 12 September, 2018, in exercise of its power
conferred under section 45-IA(6) of the RBI Act.
5. Subsequent thereto, the petitioner filed a statutory appeal impugning
the order of the Adjudicating Authority of the respondent/RBI. However,
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the said appeal was also rejected vide order dated 15 April, 2020.
6. Consequently, aggrieved by the action of the respondent/RBI
cancelling the CoR and questioning the orders of the Adjudicating
Authority as well as that of the Appellate Authority and simultaneously
challenging the constitutionality of the relevant part of section 45-1A of the
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RBI Act and notification dated 10 November, 2014, petitioner company
prefers the present petition.
CONTENTIONS ON BEHALF OF THE PETITIONER:-
7. Mr. J.M. Kalia, learned counsel for the petitioner challenges the vires
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of the notification dated 10 November, 2014, issued by the
respondent/RBI whereby the NBFCs were required to attain a minimum
NOF of Rs.200 lakhs by the end of March, 2017 on the ground that the RBI
as a delegatee could not have issued such notification for lack of legislative
competence and as such, ought to be struck down. He states that the subject
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matter of the notification dated 10 November, 2014 is already covered
under the statute in sub section (3) of section 45-IA of the RBI Act and as
such, the notification issued is an exercise beyond the purview and
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jurisdiction of the respondent/RBI. The respondent/RBI being a delegatee
cannot arrogate to itself the power of the Legislature. The RBI having done
so by issuance of the said notification has acted beyond its powers and as
such, the said notification ought to be quashed.
8. He states that the non-compliance of the provisions of clause (iv)(a)
of sub section (6) of section 45-IA of the RBI Act entails cancellation of
the CoR of an NBFC without any recourse to remedial measure for
rectifying such non-compliance by such NBFC. He states that in
contradistinction to the aforesaid, non-compliance of clauses (ii) and (iii) of
sub section (6) of section 45-IA of the RBI Act by NBFC could entail an
opportunity on terms as the RBI may deem fit, to take necessary steps to
comply with such provision or fulfillment of such condition. He submits
that the lack of similar remedial measure in the case of NBFCs falling
within clause (iv)(a) of sub section (6) of section 45-IA of the RBI Act, is
discriminatory and thus, violative of provisions of Article 14 of the
Constitution of India. He states that by virtue of the aforesaid enactment,
the Legislature has created an artificial divide in the case of NBFCs, by
providing remedial measures in case of one set of NBFCs in
contradistinction to another set of NBFCs who are not provided any
remedial measure at all. He states that there is no rationale or any nexus
much less any intelligible differentia on the basis whereof such distinction
has been drawn within the same category of NBFCs. He states that as a
consequence, clause (iv)(a) of sub section (6) of section 45-IA of the RBI
Act along with its proviso ought to be declared ultra vires the Constitution
of India.
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9. Learned counsel for petitioner invites attention to the definition of
“ Financial Institutions ” contained in sub section (c) of section 45-I of the
RBI Act to submit that the petitioner does not fall within the said definition
and as such, the provisions of Chapter III-B of the RBI Act as also the
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notification dated 10 November, 2014, cannot be made applicable to it.
He states that the petitioner is not carrying on the business of financing,
whether by way of making loans or advances or otherwise, of any activity
other than its own. He states that the petitioner is neither advancing any
loans nor receiving any public deposits and is an entity which is indulging
in such activities only with its sister companies. As a consequence, he
states that the petitioner would not fall within the aforesaid definition. In
support of the aforesaid submissions, learned counsel for petitioner also
invites attention to clause (ii) of sub section (f) of section 45-I of the RBI
Act to submit that the petitioner does not fall within the definition of NBFC
as defined thereunder. The thrust of the learned counsel is that the
petitioner does not fall within the definition of NBFC as stipulated in
section 45-I of the RBI Act and thus, cannot be compelled to comply with
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the directions contained in the notification dated 10 November, 2014.
10. As a sequitur to the aforesaid argument, learned counsel for
petitioner states that if the aim of prescribing NOF for NBFCs is to ensure
liquidity which the NBFC has to maintain to repay the public deposit, the
same cannot be made applicable to the present petitioner since the
petitioner, though being an NBFC had voluntarily not obtained any
certificate authorizing it to accept public deposits in the first place. He thus
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submits that the present petition be allowed and the notification dated 10
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November, 2014 and the clauses of section 45-I of the Act be declared
unconstitutional.
CONTENTIONS ON BEHALF OF THE RESPONDENT:-
11. Per contra , Mr. Ramesh Babu, learned Standing Counsel for the
respondent/RBI refutes the contentions of the petitioner. He states that the
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notification dated 10 November, 2014 has been issued by the
respondent/RBI in exercise of the powers conferred upon it by virtue of
section 45-I and 45-J of the RBI Act and as such, cannot be challenged on
the grounds of unconstitutionality or lack of competence. He submits that
the provisions of the aforementioned sections manifestly empower the RBI
to not only supervise but also regulate the NBFCs. He states that the bogey
of lack of competence or unconstitutionality has been raised by the
petitioner after having availed of the efficacious remedy provided under
section 45-I of the RBI Act and failed thereunder.
12. Learned counsel for respondent submits that this Court in Jeevan
Holding Pvt. Ltd. and Ors. Vs. Union of India and Ors. 283 (2021) DLT
579 , has already considered the very same provisions challenged in the
present writ petition, and though the constitutionality of the said provisions
was not in issue, yet, has found them to be in consonance with the other
provisions of the RBI Act. Though not in issue, yet, no repugnancy was
found either. He specifically relies upon paragraph 5 of the said judgement
wherein the Coordinate Bench had extracted the paragraphs from the
learned Single Judge’s order, in support of his contentions.
13. He also submits that the petitioner is covered within the definition of
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NBFC as stipulated in clause (ii) sub section (f) of section 45-I under
Chapter III-B of the RBI Act and as such, it cannot be contended that the
petitioner is not bound by the provisions thereunder. He submits that the
petitioner has been granted the CoR under Chapter III-B of the RBI Act
and has been conducting its business operations by virtue thereof at least
from the year 1998. He also states that thus, the petitioner is bound by the
terms of the CoR, one of which is to comply with the notifications/circulars
issued by RBI from time to time. He states that having availed of the CoR
to conduct its business, it does not lie in the mouth of the petitioner to
contend that the provisions of section 45-I of the RBI Act or the
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notification dated 10 November, 2014 is unconstitutional. He states that in
any case, the petitioner cannot complain that the principles of natural
justice or that its fundamental rights have been violated. In order to buttress
his arguments, learned counsel for the respondent/RBI relies upon the
judgement in the case of Jeevan Holding (supra) , to submit that the
reasonable opportunity of being heard does not necessarily mean an “Oral
Hearing” and the same is held to be duly complied with, if the aggrieved is
provided with an opportunity to file its reply to the SCN and the same has
been considered while passing the order. In the same breath, he submits
that even in the present case, there is no violation of the principles of
natural justice since the petitioner was, (i) issued a show cause notice under
section 45-IA(6)(i-v); (ii) reply to the same accepted by the Competent
Authority; (iii) considered and rejected in accordance with the law.
Thereafter, the petitioner even availed of the statutory appeal which was
dismissed with a reasoned and speaking order. He states that the present
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writ petition is nothing but an abuse of the process of law and ought to be
dismissed with costs.
ANALYSIS & CONCLUSIONS:-
14. We have heard Mr. J.M. Kalia, learned counsel for the petitioner,
Mr. Ramesh Babu, learned Standing Counsel for respondent/RBI, perused
the record and considered the relevant judgments relied upon.
15. Since the petitioner has challenged the vires of the notification dated
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10 November, 2014 as also clause (iv)(a) of sub section 6 of section 45-IA
of the RBI Act, it would be appropriate to first examine the scope and
jurisdiction of a Constitutional Court while examining the constitutionality
of a particular provision of a Statute. In this regard, it would be enriching to
consider the judgment of the Supreme Court in Peerless General Finance
and Investment Co. Limited vs. Reserve Bank of India, (1992) 2 SCC 343 .
The relevant paragraphs of the same are reproduced as under:-
“48. However, there is presumption of constitutionality of every statute and
its validity is not to be determined by artificial standards. The Court has to
examine with some strictness the substance of the legislation to find what
actually and really the legislature has done. The Court would not be over
persuaded by the mere presence of the legislation. In adjudging the
reasonableness of the law, the Court will necessarily ask the question
whether the measure or scheme is just, fair, reasonable and appropriate or
is it unreasonable, unnecessary and arbitrarily interferes with the exercise
of the right guaranteed in Part III of the Constitution.
49. Once it is established that the statute is prima facie unconstitutional, the
State has to establish that the restrictions imposed are reasonable and the
objective test which the Court is to employ is whether the restriction bears
reasonable relation to the authorised purpose or is an arbitrary
encroachment under the garb of any of the exceptions envisaged in Part III.
The reasonableness is to the necessity to impose restriction; the means
adopted to secure that end as well as the procedure to be adopted to that
end.
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xxx xxx xxx
51. This Court in Joseph Kuruvilla Vellukunnel v. Reserve Bank of India
AIR 1962 SC 1371 held that the RBI is "a bankers" bank and lender of the
last resort". Its objective is to ensure monetary stability in India and to
operate and regulate the credit system of the country. It has, therefore, to
perform a delicate balance between the need to preserve and maintain the
credit structure of the country by strengthening the rule as well as apparent
creditworthiness of the banks operating in the country and the interest of the
depositors. In underdeveloped country like ours, where majority population
are illiterate and poor and are not conversant with banking operations and
in underdeveloped money and capital market with mixed economy, the
Constitution charges the State to prevent exploitation and so the RBI would
play both promotional and regulatory roles. Thus the RBI occupies place
of "pre-eminence" to ensure monetary discipline and to regulate the
economy or the credit system of the country as an expert body. It also
advices the government in public finance and monetary regulations. The
banks or non-banking institutions shall have to regulate their operations
in accordance with, not only as per the provisions of the Act but also the
rules and directions or instructions issued by the RBI in exercise of the
power thereunder. Chapter 3-B expressly deals with regulations of deposit
and finance received by the RNBCs. The directions, therefore, are statutory
regulations.”
(emphasis supplied)
16. In the same light, it would also be apposite to consider another
judgment of the Supreme Court in Public Services Tribunal Bar
Association vs. State of U.P. and Another, (2003) 4 SCC 104 . The
relevant paragraphs of the same are reproduced as under:-
“26. The constitutional validity of an Act can be challenged only on two
grounds viz. (i) lack of legislative competence; and (ii) violation of any of
the fundamental rights guaranteed in Part III of the Constitution or of
any other constitutional provisions. In State of A.P. v. McDowell & Co.
(1996) 3 SCC 709 this Court has opined that except the above two grounds
there is no third ground on the basis of which the law made by the
competent legislature can be invalidated and that the ground of
invalidation must necessarily fall within the four corners of the
aforementioned two grounds.
27. Power to enact a law is derived by the State Assembly from List II of the
Seventh Schedule of the Constitution. Entry 41 confers upon a State
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Legislature the power to make State Public Services; State Public Services
Commission. Under this entry, a State Legislature has the power to
constitute State Public Services and to regulate their service conditions,
emoluments and provide for disciplinary matters etc. The State Legislature
had enacted the U.P. Public Services Tribunals Act, 1976 in exercise of the
power vested in it by Entry 41 of List II of the Seventh Schedule. Power to
enact would include the power to re-enact or validate any provision of law
in the State Legislature provided the same falls in an entry of List II of the
Seventh Schedule of the Constitution with the restriction that such
enactment should not nullify a judgment of the competent court of law. The
legislative competence of the State to enact the U.P. Public Services
Tribunal has not been questioned in these appeals. The challenge put forth
to various amendments made is that the same are violative of Articles 14
and 16 of the Constitution being arbitrary as they are onerous and work
inequitably. In the present appeals legislative action of the State is under
challenge. Judicial system has an important role to play in our body
politic and has a solemn obligation to fulfil. In such circumstances it is
imperative upon the courts while examining the scope of legislative action
to be conscious to start with the presumption regarding the constitutional
validity of the legislation. The burden of proof is upon the shoulders of the
incumbent who challenges it. It is true that it is the duty of the
constitutional courts under our Constitution to declare a law enacted by
Parliament or the State Legislature as unconstitutional when Parliament or
the State Legislature had assumed to enact a law which is void, either from
want of constitutional power to enact it or because the constitutional forms
or conditions have not been observed or where the law infringes the
fundamental rights enshrined and guaranteed in Part III of the
Constitution.”
(emphasis supplied)
17. It is trite that there is a presumption of constitutionality of a
particular statute and no Court would easily infer that a particular provision
of law is unconstitutional for the mere asking. The grounds of challenge to
such constitutionality are within a narrow prism, in that, as laid down by
the aforesaid judgments i.e., (i) lack of legislative competence and (ii)
violation of any fundamental right guaranteed under Part III of the
Constitution of India, 1950. It is also a settled law that the onus to disprove
is upon the person challenging it. In Peerless ’s case (supra) , the Supreme
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Court was dealing with a challenge to the constitutionality of directions
issued by the RBI to certain Public Sector Banks and residuary non-
banking companies. While considering the challenge to the
constitutionality, the Supreme Court had observed that in the context of the
Indian Economy, the Constitution charges the State to prevent exploitation
and concluded that the RBI would play both promotional and regulatory
roles. The RBI is considered to occupy a place of “pre-eminence” to ensure
monetary discipline and to regulate the economy or the credit system as an
expert body. The RBI also advises the Government in Public Finance and
Monetary Regulations. It is a well known fact that the banks and non-
banking institutions shall have to regulate their operations in accordance
with not only the Act but also the Rules, directions or instructions issued by
the RBI. The Supreme Court appears to suggest that the directions issued
by the RBI under the RBI Act are in the nature of Statutory Regulations.
The same were also held to be incorporated and become part of the Act
itself. The conclusion appears to be that while testing the challenge of
constitutionality to the directions issued by RBI, it needs to be looked at as
if the same is a challenge to the vires of the statute itself. Given this
background, we need to test the challenge laid.
18. Apart from contending that the RBI is a delegatee and lacks the
competence to issue such directions as contained in the notification dated
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10 November, 2014, neither any demonstrable material nor even a shred
of evidence or any compelling argument has been put across by the
petitioner to convince us of any challenge at all, much less a demonstrable
challenge. Keeping in view the fact that the Supreme Court in Peerless
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(supra) has categorically repelled a similar challenge to the directions
passed by the RBI, we see no reason, much less any cogent reason or a
ground raised by the petitioner to doubt the presumption of
constitutionality of the directions in the said notification. Besides, in
Peerless (supra) , the Apex Court had already upheld the competence of the
RBI to issue notifications and other necessary directions to both, Banks and
NBFCs in furtherance of the aims and objects of the Act. Thus, the
question of lack of competence is no more res integra .
19. The other ground urged by learned counsel was in respect of an
imaginary violation of fundamental rights as also the principles of natural
justice. This was in the context of the comparison between the effect of
non-compliance of provisions of clause (iv)(a) of sub section 6 of section
45-IA on the one hand and clauses (ii) and (iii) of sub section 6 of section
45-IA of the RBI Act on the other. Learned counsel sought to demonstrate
that in case an action against an NBFC is contemplated under clause
(iv)(a), no opportunity to rectify such non-compliance is stipulated,
whereas non-compliance of clauses (ii) and (iii) entail an opportunity to
take steps to comply with the provision or direction given by the RBI.
Though learned counsel has raised this ground, we find from the facts
obtaining on record that the RBI had, admittedly, issued a SCN invoking,
primarily, non-compliance under clause (ii) of sub section 6 of section 45-
IA of the RBI Act. That apart, an opportunity to reply was also afforded to
the petitioner. Moreover, the petitioner had also challenged the order
arising from the SCN before the Appellate Authority as contemplated by
the proviso to the aforesaid clause. It is this order of the Appellate
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Authority which is being challenged here.
20. It is apparent from the aforesaid undisputed and admitted facts that
the RBI had not only complied with the principles of natural justice as also
the statutory requirements of the regulations and the Act but also
unquestionably not violated any Fundamental Right as envisaged in Part III
of the Constitution of India of the petitioner. Thus, even this submission
fails. In view of the above, we hold that the petitioner has been unable to
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successfully lay a challenge to the vires of either the notification dated 10
November, 2014 or even provisions of the RBI Act.
21. With respect to the submission regarding the petitioner not falling
within the definition of “ Financial Institutions ” as stipulated in sub-section
(c) of section 45-I of the RBI Act, we find that the petitioner would fall
squarely within the meaning of “ Non-Banking Financial Company ” as
defined in sub section (f) of section read with clause (i) of sub section (c)
of section 45-I and sub section (e) of section 45-I of the RBI Act. Having
regard to the aforesaid, it is unfathomable as to on what basis the petitioner
claims to be not an NBFC falling within the definitions contained in
Chapter III-B of the RBI Act. The contention of the learned counsel that
since the petitioner voluntarily does not accept public deposit, such non
acceptance would automatically extricate it from the definitions so
contained in the Act is concerned, suffice it to state that no such embargo is
discernible either from the provisions of the Act or from the CoR issued to
the petitioner. To be more clear, the conditions of the CoR as annexed in
the present petition at page 38, are reproduced hereunder:-
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-In vernacular-
1. The Certificate of Registration or a certified copy
thereof shall be kept displayed at the Registered Office and
other offices, branches, if any, of your company.
-In vernacular-
2. The Certificate of Registration is issued to your company
subject to your continued adherence to all the conditions
and parameters stipulated under Chapter III B of the
Reserve Bank of India Act, 1934.
-In vernacular-
3. Your company shall be required to comply with all the
requirements of the Directions, guidelines / instructions,
etc. issued by the Bank and as applicable to it.
-In vernacular-
4. If your company desires to indicate directly or indirectly
in any advertisement. etc. that the company is having a
Certificate of Registration issued by the Reserve Bank of
India. such advertisement should invariably contain a
statement as under :-
"The company is having a valid Certificate of Registration
dated 3•3•1998 issued by the Reserve Bank of India under
section 451A of the Reserve Bank of India Act, 1934.
However, the Reserve Bank of India does not accept any
responsibility or guarantee about the present position as to
the financial soundness of the company or for the
correctness of any of the statements or representations
made or opinions expressed by the company and for
repayment of deposits / discharge of liabilities by the
company.”
-In vernacular-
5.* Your company must not accept any public deposit for
the time being. After the company has been in operation
for a period of two years, if it intends to raise public
deposits, it may approach the Bank with the audited
Balance Sheets for two years and a credit rating for fixed
deposits from one of the recognized rating agencies. Your
company will accept public deposit only after obtaining
specific approval from us.
-In vernacular-
6. The date when your company has commenced business
as a non-banking financial institution may be advised to the
Bank.
-In vernacular-
Applicable to new companies incorporated on or after *
January 9, 1997.
(emphasis supplied)
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22. It is apparent from the perusal of the CoR that the embargo, if any,
contained in para 5 of the conditions was only till two years of the
commencement of the operations of the petitioner. Thereafter, the
petitioner could, if so desired, approach the RBI for approval to accept
public deposits. Thus, the aforesaid submission is noted only to be rejected.
23. We have also examined the provisions of section 45-JA of the RBI
Act and find that the legislature has vested/conferred statutory power upon
the RBI, in public interest, to determine the policies or to regulate the
financial system of the country and to prevent the affairs of any NBFC
being conducted in a manner detrimental to the interests of the depositors
or in a manner prejudicial to the interests of the NBFC. Thus, the
legislature seems to have conferred ample powers and jurisdiction upon the
respondent/RBI to take all steps necessary to safeguard the financial
interests of the country.
24. No other ground of challenge was either raised or addressed by
learned counsel for the petitioner.
25. In view of the above, we are of the considered opinion that the
present writ petition is devoid of any merit and is dismissed alongwith
applications, though without any order as to costs.
TUSHAR RAO GEDELA, J
ACTING CHIEF JUSTICE
/rl/aj
August 20, 2024
Signature Not Verified
Digitally Signed
By:MADHU SARDANA
Signing Date:30.08.2024
17:22:40
W.P.(C) 10690/2021 Page 16 of 16