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Supreme Court of India validates exclusive jurisdiction clauses in employment contract easing litigation for employers

In a significant development for employers navigating the complexities of a diverse workforce, the Hon’ble Supreme Court of India (“Supreme Court”) has recently upheld the validity of exclusive jurisdiction clauses in employment contracts.

In the case of Rakesh Kumar Varma vs. HDFC Bank Limited and HDFC Bank Limited vs. Deepti Bhatia[1], the Supreme Court has clarified that when employees sign agreements with their employers specifying a particular court for dispute resolution, even if it’s distant from the place of posting, such clauses can be valid.

This decision ensures that employers can confidently designate a specific jurisdiction for legal disputes, even if their workforce is geographically dispersed. For employers managing a pan-India presence, this judgment serves as a beacon of relief, eliminating the daunting prospect of litigating in multiple states merely due to the geographical distribution of their employees.

Brief facts

The matter involved 2 (two) former employees of HDFC Bank Limited (“HDFC Bank”), who filed suits in courts located at places of their employment, that is, Patna and Delhi respectively.

The appointment letters included an ‘exclusive jurisdiction clause’, specifying that only the courts in Bombay would have jurisdiction over any disputes arising from their employment. Upon termination of their services based on allegations of fraud and misconduct, aggrieved by the termination, both employees instituted a civil suit before the courts in Patna and New Delhi, respectively. In response, HDFC Bank sought rejection of the plaint, arguing that only the courts in Mumbai had jurisdiction, as per the terms of the employment contract.

While the Patna High Court (“Patna HC”) ruled in favour of HDFC Bank and upheld the validity of the exclusive jurisdiction clause, with respect to the second employee, both the trial court as well as the Delhi High Court (“Delhi HC”) held that the exclusive jurisdiction clause in favour of courts in Bombay did not completely oust the jurisdiction of the Delhi courts and accordingly dismissed HDFC Bank’s argument.

The Patna HC relied primarily on the Supreme Court’s ruling in Swastik Gases (P) Limited vs. Indian Oil Corporation[2], to uphold the validity of the exclusive jurisdiction clause. The Supreme Court observed that although, as per general principles under the Code of Civil Procedure, 1908 (“CPC”), a suit can be instituted at any place where a substantial part of the cause of action arises, this right can be contractually limited by the parties. When parties have expressly agreed to confer exclusive jurisdiction upon a particular court, in this case, the courts in Bombay, such a clause must be respected, provided the chosen court has jurisdiction under the law in the first place.

In contrast, the Delhi HC dismissed HDFC Bank’s jurisdictional objection. The Delhi HC emphasised that the employee was residing and employed in Delhi, and that her termination letter was served upon her in Delhi. On these grounds, the Delhi HC held that part of the cause of action did arise within its territorial jurisdiction. Relying on the precedent in Vishal Gupta vs. L&T Finance, the Delhi HC held that the exclusive jurisdiction clause in the employment agreement did not fully oust the jurisdiction of courts in Delhi, especially when significant parts of the cause of action occurred within that jurisdiction.

Issue

The question for consideration was whether the civil suits filed by the employees before the courts in Patna and Delhi respectively, are maintainable in light of the exclusive jurisdiction clause contained in their appointment letters/employment agreements, which expressly conferred jurisdiction upon the courts in Mumbai for the resolution of disputes arising out of their employment with HDFC Bank.

Analysis and key observations

• Applicable provisions of law: Before delving into an appreciation of the competing claims, let us first examine the relevant statutory provisions governing the matter:
  • Section 28 (Agreements in restrain of legal proceedings, void) of the Indian Contract Act, 1872 (“Contract Act”) renders void any agreement that seeks to impose an absolute restriction on a party’s right to enforce their contractual claims through the ordinary tribunal. It also invalidates clauses that either limit the timeframe within which such rights can be enforced or extinguish legal rights altogether after a specified period; and
  • Section 20 of the CPC sets out the rules for determining the appropriate jurisdiction for filing a civil suit. It provides that a suit may be instituted in a court within whose jurisdiction the defendant resides, carries on business, or where the cause of action, wholly or in part, arises. The explanation to the provision also provides that in cases involving corporations, the law deems them to carry on business either at their principal office or at a subordinate office if the cause of action arises at that place.
• Judicial Precedents: The Supreme Court referred to the landmark judgment in Hakam Singh vs. Gammon (India) Limited.[3], wherein the Supreme Court held that while parties cannot confer jurisdiction on a court that does not have it under the CPC, they may agree to have disputes adjudicated in one of the multiple courts that do have jurisdiction. Such an agreement is neither opposed to public policy nor does it violate Section 28 of the Contract Act. Similarly, in Globe Transport Corporation vs. Triveni Engineering Works[4], the Supreme Court re-affirmed that contracting parties may lawfully agree to exclude the jurisdiction of all courts except one, as long as the chosen court has jurisdiction under the law. Subsequently, in Swastik Gases (P) Ltd. vs. Indian Oil Corporation[5], the Supreme Court clarified that the use of words such as ‘only’, ‘alone’, or ‘exclusive’ in a jurisdiction clause, is also not strictly necessary to infer that the parties’ intend to restrict jurisdiction to a specific court. The Supreme Court accordingly pointed out that when a contract contains a jurisdiction clause specifying a particular court or forum, this clause will generally be interpreted as an intent to exclude the jurisdiction of all other courts.
• Legal test for validity of exclusive jurisdiction clauses: Drawing reference to the various judicial precedents, the Supreme Court emphasised that for an exclusive jurisdiction clause to be legally valid, it must satisfy the following 3 (three) conditions:
  • The provision should not be violative of Section 28 of the Contract Act: Section 28 of the Contract Act does not prohibit exclusive jurisdiction clauses. What this section specifically bars is any agreement that imposes an absolute restriction on a party’s right to access a legal forum. In other words, while parties cannot be entirely denied the right to pursue legal action, they can agree contractually to limit the forums available to them. In the present case, the jurisdiction clause in the employees’ employment contracts does not strip them of their right to seek legal redress. Rather, it confines their choice of forum to the courts in Mumbai alone, for the resolution of disputes arising from their employment.
  • The chosen court should have jurisdiction in the first place: It is essential that the court specified in the exclusive jurisdiction clause must, at the outset, have jurisdiction to adjudicate the dispute. A contract cannot bestow jurisdiction upon a court that does not already possess it under the statutory framework. In this case, the Supreme Court applied the explanation to Section 20 of the CPC and found that:
    • the decision to appoint and terminate both the employees was taken in Mumbai;
    • the appointment and termination letters were issued and dispatched from Mumbai; and
    • HDFC Bank’s principal office is located in Mumbai.

Thus, the courts in Mumbai are found to have jurisdiction over the dispute, as both the cause of action and the administrative processes that led to the termination took place in Mumbai.

• • Clear intention of exclusivity: Finally, the language of the jurisdiction clause in both contracts is clear and unambiguous in designating Mumbai as the sole jurisdiction for resolving disputes. By using the term ‘exclusive’ the clause explicitly bars the jurisdiction of other courts.

The Supreme Court also acknowledged the growing reality that private sector employers operate on a pan-India scale, employing individuals across the country to provide services that reach people in the last mile. In this context, the Supreme Court recognised the practical challenge faced by employers when they are required to contest legal suits in jurisdictions far from their registered offices. This challenge, the Supreme Court noted, is one of the key reasons behind the inclusion of exclusion clauses in employment contracts and is justified.

Further, the Supreme Court addressed the issue of the imbalance of power between the contracting parties. It rejected the idea of differentiating employment contracts from other types of contracts on the basis of an exaggerated analogy, where the employer is likened to a ‘mighty lion’ and the employee to a ‘timid rabbit’. Such a distinction, the Supreme Court highlighted, would undermine the principle of equality, as rights and obligations should not depend on the parties’ relative status, power, or influence. The Supreme Court emphasised that unequal bargaining power is not unique to personal service contracts; it is a broader issue that affects all contracts and noted that the “law treats all contracts with equal respect and unless a contract is proved to suffer from any of the vitiating factors, the terms and conditions have to be enforced regardless of the relative strengths and weakness of the parties.”

The Supreme Court ultimately upheld HDFC Bank’s contention that, in view of the valid and enforceable exclusive jurisdiction clauses in the respective employment contracts, the suits instituted by the employees ought to have been filed before the appropriate courts in Mumbai.

Conclusion

As workplaces evolve and businesses expand, this decision offers crucial clarity and relief for employers managing a geographically diverse workforce. By affirming the enforceability of exclusive jurisdiction clauses, the  Supreme Court has clarified that such clauses are not inherently void or oppressive, provided they satisfy the conditions for a valid exclusion clause.

This ruling is especially pertinent in today’s increasingly remote/hybrid and pan India work environment. As employees continue to work from home or from locations geographically distant from their employer’s principal place of business, this decision effectively empowers employers to anchor legal disputes to the jurisdiction of their choice. In practice, this means that even if an employee is working from a different city, or a different state, the employer can validly require all employment-related disputes to be adjudicated only in the courts at the employer’s chosen location in the employment contract, provided such court has jurisdiction under law to adjudicate the matter.

By allowing parties to designate a specific jurisdiction for disputes, the Supreme Court has not only streamlined the litigation process but also mitigated the complexities of navigating multiple legal frameworks in different states. Employers can now approach disputes with greater confidence, knowing that they can rely on a pre-determined legal framework, ultimately fostering a more stable and predictable business environment. In this way, the Supreme Court’s decision not only upholds contractual autonomy but also supports the broader goal of facilitating efficient and effective business operations across India.

This Prism has been prepared by:

Preetha S Partner

Rebecca Thomas Associate

For more details, please contact [email protected].

[1]  Civil Appeal Nos. 2282/2025 and 2286/2025

[2]  (2013) 9 SCC 32

[3]  (1971) 1 SCC 286

[4] (1983) 4 SCC 707

[5]  (2013) 9 SCC 32

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Andhra Pradesh eases working conditions for the Information Technology and Information Technology-Enabled Services sector to boost operational flexibility

In 2002, the Government of Andhra Pradesh first issued a notification exempting Information Technology (“IT”) and IT-Enabled Services (“ITeS”) establishments from certain provisions of the Andhra Pradesh Shops and Establishments Act, 1988 (“AP S&E Act”), for a period of 5 (five) years, effective from May 30, 2002. This exemption has been renewed periodically to support the growth of the IT and ITeS sector within the State. Most recently, on March 25, 2025, the Andhra Pradesh government issued a new notification (“AP Exemption 2025”), which further extends the exemption under the AP S&E Act for a period of 5 (five) years, effective from March 25, 2025, subject to fulfilment of certain conditions. This move underscores the State Government’s continued commitment to creating a conducive environment for the IT/ITeS sectors, which remain a cornerstone of the state’s economic growth.

Key features and conditions of the AP Exemption 2025

The AP Exemption 2025 offers IT/ITeS companies with greater flexibility by relaxing several operational provisions. This includes exemptions from restrictions on opening and closing hours[1], daily and weekly work hours[2], as well as the employment of young persons before 6:00 am and after 7:00 pm[3]. Additionally, the exemption, subject to certain safety and security conditions, allows for the employment of women in night shifts[4] which was already permitted under the 2018 amendment to the AP S&E Act. It also facilitates operations on national and festival holidays[5], and simplifies conditions related to employee terminations and the payment of service compensation[6].

Under the AP Exemption 2025, IT/ITeS establishments in the State are allowed to operate round the clock and implement flexible work arrangements as needed. However, this exemption is accompanied by a clear set of conditions designed to protect the rights and welfare of employees.

The AP Exemption 2025 also makes it clear that in the event of non-compliance with any of the stipulated conditions, the exemption may be revoked without any prior notice.

The exemption granted to IT/ ITeS establishments is subject to the following conditions, to ensure the welfare of employees, while promoting ease of doing business:

1. Working hours and overtime wages: The AP S&E Act prescribes a standard 8 (eight) hour workday with a weekly cap of 48 (forty-eight) hours limiting the total working hours (inclusive of overtime) to 12 (twelve) hours per day and 62 (sixty-two) hours per week. It also restricts overtime work exceeding 7 (seven) consecutive days and caps overtime hours to a maximum of 50 (fifty) hours per month.

Under the AP Exemption 2025, the weekly hours are capped at 48 (forty-eight) hours and any work done beyond such threshold would trigger the obligation to pay overtime wages. However, the AP Exemption 2025 does not limit the maximum number of overtime hours an employee can work on a daily, weekly, or monthly basis, nor does it prohibit employers from requiring employees to work overtime on consecutive days.

2. Weekly Off: Irrespective of the exemptions, a weekly-off day must necessarily be granted to every employee.
3. Engaging female employees and young persons during night shifts: An establishment is permitted to engage young persons and female employees during night shifts, that is between 8:30 pm to 6:00 am. However, unlike in the case of Telangana, where the exemption conditions applicable to IT/ITeS establishments specifically require employers to provide adequate security during the shift and transportation to both young persons and female employees, the AP Exemption 2025 casts such obligations specifically for the safety and security of female employees engaged during night shifts, which are set out below:
   • Security and transportation: Female employees will be provided with adequate security and transportation to and from their residences.
   • Driver screening and verification: Employers must obtain the biodata of each driver and conduct thorough pre-employment screenings to verify the antecedents of all drivers, whether employed directly or through outsourcing. Information such as the driver’s driving license, photograph, address, mobile number, and other relevant details must also be retained by the employer.
   • Pick-up and drop-off schedules: The schedule and route for pick-up and drop-off of female employees must be planned by the supervisory officer of the establishment every Monday. If Monday is a holiday, the schedule will be prepared the following working day. In cases of emergency, changes to the driver, route, or shift may be made but only with prior knowledge of the supervisory officers and the employees.
   • Confidentiality of personal information: The telephone number, particularly mobile phone numbers and addresses of the female employees must not be disclosed to unauthorised persons.
   • Route Selection: Careful selection of routes must be made such that no female employee is picked up first or dropped last.
   • Security guards: While not mandatory, security guards may be deployed for female employees during cab drop-offs and pick-ups. The timings as recommended in the AP Exemption 2025 is before 6:00 am and after 8:00 pm.
   • Random vehicle checks and GPS monitoring: The designated supervisors of the establishment are required to conduct a random on the vehicle on various routes. Further, establishments are required to have a control room for GPS based vehicle movement monitoring, and to have vehicles registered under the VAHAN app besides ensuring that female employees have downloaded the security mobile app of the police department.
   • CCTV surveillance: The boarding and alighting points must be equipped with CCTV cameras, either installed by the police department or by the establishment, to monitor the safety of female employees.

While the AP Exemption 2025 introduces more robust safety-related provisions, ensuring enhanced security and safer commuting for women working in night shifts, by granting a blanket exemption from all provisions related to women working in night shifts under the AP S&E Act, the AP Exemption 2025 seems to have removed certain additional safeguards, that were previously afforded to female employees under the AP S&E Act. For example, the AP S&E Act prohibits women from working in night shifts for 16 (sixteen) weeks before and after childbirth, which was more beneficial than the restricted period set out under the Maternity Benefit Act, 1961.

4. Identity cards: Every employee must also be provided with identity cards and other welfare measures to which they are eligible as per the extant applicable laws.
5. Compensatory holiday: Employees working on a notified holiday must mandatorily be given a compensatory holiday in lieu of notified holiday worked, with wages.
6. Statutory registers: Employers are permitted to maintain registers under the AP S&E Act in soft copies.
7. Online filing of returns: Employers shall file returns of employees in accordance with directions issued by the Labour Factories Boilers and Insurance Medical Service Department on the Ease of Doing Business/Industries department websites.

Termination related exemptions

While several states like Telangana, Gujarat, and Uttar Pradesh, have previously rolled out exemptions for the IT/ITeS sector, primarily addressing work hours, overtime, and employment of women during night shifts; the AP Exemption 2025 interestingly takes a distinct approach by also offering certain exemptions related to employee terminations. Accordingly, the provisions inter alia require employers to provide a 1 (one) month notice or payment in lieu of notice upon termination of employment (for employees who have completed 6 (six) months of employment), the requirement to pay ‘service compensation’ to those employees who have completed at least 1 (one) year of continuous service, the requirement to notify the inspector within a prescribed period when terminating an employee etc., have been removed. Having said that, the termination related protections as available under other applicable labour laws including the Industrial Disputes Act, 1947 will continue to apply.

Conclusion

The extension of the exemption for IT/ ITeS companies in Andhra Pradesh for an additional 5 (five) years is undoubtedly a welcome relief for employers, providing them with increased operational flexibility. By renewing the exemption, the government is ensuring that these sectors continue to thrive with significantly fewer restrictions, which is crucial for their global competitiveness. Having said that, while these exemptions are beneficial, certain conditions could have been better aligned with the realities of today’s modern workforce. For instance, the mandate to provide transportation for women working in night shifts is well-intentioned, yet many employees prefer using their personal means of transportation. This raises important questions regarding employers’ obligations and liabilities in such scenarios. Likewise, installing CCTV surveillance at boarding and drop points can pose practical challenges for employers adding to their operational complexities.

These exemptions will also be essential to ensure that the broader objectives of employee welfare, fair treatment, and workplace equity are not compromised in the pursuit of operational efficiency. Employers should therefore advocate for a framework that recognises the evolving preferences of the workforce while ensuring compliance with the law.

By fostering an environment that values flexibility alongside responsible employee welfare, a more productive and harmonious workplace can be created, which benefits both organisations and its employees.

This Prism has been prepared by:

Preetha S Partner

Rebecca Thomas Associate

Sneha Mohanty Associate

For more details, please contact [email protected].

[1] Section 15 of the AP S&E Act.

[2] Section 16 of the AP S&E Act.

[3] Section 21 of the AP S&E Act.

[4] Section 23 of the AP S&E Act.

[5] Section 31 of the AP S&E Act.

[6] Sub section (1), (2), (3) and (4) of Section 47 of the AP S&E Act.

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Gratuity forfeiture permissible without criminal conviction for misconduct involving moral turpitude

In a recent case that signals a shift in the judicial interpretation, the Hon’ble Supreme Court of India (“Supreme Court”) in the case of Western Coal Fields Ltd vs. Manohar Govinda Fulzele[1] has ruled that a criminal conviction would not be necessary to forfeit an employee’s gratuity, if the employee’s services are terminated for an offence involving moral turpitude, which has been established through a disciplinary inquiry conducted by the employer.

This ruling diverges from the traditional stance which typically required a court conviction prior to imposing punitive measures such as forfeiture of gratuity. This ruling underscores the need to uphold ethical standards within the workplace, pointing towards the fact that actions reflecting moral failing can carry serious repercussions, regardless of criminal proceedings.

The law on forfeiture of gratuity

Under the Payment of Gratuity Act, 1972 (“Gratuity Act”), gratuity (a monetary benefit paid to separating employees who have completed at least 5 (five) years of service, payable at the time of separation), can be partially or fully forfeited by an employer in certain limited circumstances amounting to misconduct. Among other circumstances, Section 4(6)(b)(ii) of the Gratuity Act permits an employer to forfeit an employee’s gratuity, if their services are terminated for committing an offence involving moral turpitude, provided such offence occurred during the course of employment.

Brief facts

In the instant case, an employee who had served for nearly 22 (twenty-two) years with a public sector undertaking (“PSU”) faced disciplinary action for misconduct related to submitting a fraudulent date of birth certificate during their initial appointment to secure employment with the PSU. The disciplinary inquiry revealed that the employee was actually born in 1953, whereas the submitted date of birth at the time of appointment indicated the year of birth as 1960, thereby substantiating the charges of misconduct. Consequently, under Section 4(6)(b)(ii) of the Gratuity Act, the employee’s gratuity was forfeited when his services were terminated for committing an offence involving moral turpitude.

The present case was clubbed with similar appeals involving other employees of the Maharashtra State Road Transport Corporation (“MSRTC”), where conductors in MSRTC-operated stage carriages were found guilty of misappropriating fares collected from passengers.

The employees contested the forfeiture of their gratuity, based on the ruling in the case of Union Bank of India vs. C.G. Ajay Babu[2] (“Ajay Babu Case”) wherein the Supreme Court had held that a criminal conviction would be necessary for forfeiture of gratuity, if the employee’s services are terminated due to an offence involving moral turpitude. The employees’ counsel also argued that the employee had served for 22 (twenty-two) years in the PSU, and that the gratuity amount was the result of their dedicated service. They emphasised that the employee’s record with the PSU had been flawless, and that gratuity was a statutory right that cannot be denied upon termination of employment.

In response, the PSU contended that, irrespective of the employee’s otherwise unblemished tenure, the employee would not have been employed with the PSU had the true date of birth been disclosed at the time of appointment. The PSUs’ counsel relied on judicial precedents that suggested that the suppression of material facts during the hiring process constitutes an offence involving moral turpitude and accordingly argued that the employee’s conduct in withholding such critical information constituted an act of moral turpitude, which was substantiated through a disciplinary inquiry.

Issues

The Supreme Court examined the following issues:

1. whether or not gratuity can be forfeited in the event of termination of service on the grounds of misconduct, in case such act of misconduct is categorised as ‘an act constituting an offence involving moral turpitude’, without there being any conviction in a criminal case or even a criminal proceeding being initiated? and
2. whether forfeiture of gratuity of such terminated employee should be in part or whole?

Analysis and key observations

The Supreme Court emphasised that the interpretation adopted in the Ajay Babu Case did not arise from the language of the statutory provision (that is, Section 4(6)(b)(ii) of the Gratuity Act). Specifically, the requirement for misconduct to be ‘duly established by a court of law’ was not part of the statutory text and therefore cannot be read into it. Moreover, the text of the law prescribes that an employee should have been ‘terminated for any act which constitutes an offence involving moral turpitude’. The Supreme Court drew reference to the definition of ‘offence’ under the General Clauses Act, 1897, which is defined as ‘any act or omission made punishable by any law for the time being’. A reading of this provision suggests that there is no requirement for a court ‘conviction’.

The Supreme Court further distinguished between the evidentiary standards in criminal proceedings and disciplinary inquiries and observed that while a criminal case requires proof ‘beyond a reasonable doubt’, a disciplinary inquiry operates under the lower standard of ‘preponderance of probabilities’. Drawing parallels, the Supreme Court clarified that the forfeiture of gratuity provision does not spell out the need for conviction in a criminal proceeding as a pre-requisite to forfeit gratuity. Instead, forfeiture can be triggered if the charges of misconduct for an offence involving moral turpitude are substantiated through a disciplinary inquiry, even in the absence of a criminal conviction. In this respect, the Supreme Court further opined that in order to forfeit gratuity, an employer will need to necessarily issue a notice to the terminated employee, allowing the employee to represent both on the question of the nature of the misconduct, that is, whether it constitutes an offence involving moral turpitude, and the extent to which such forfeiture can be made.

Regarding whether gratuity should be fully or partially forfeited, the Supreme Court ruled that the gravity/severity of the misconduct should dictate the extent of forfeiture. In this context, with reference to the PSU where the appointment of the employee was illegal, the Supreme Court opined that the employee must in no manner seek the fruits of his employment by receiving gratuity as he would not have been employed in the first place had his accurate date of birth been disclosed. As a result, the Supreme Court upheld the decision to forfeit the employees’ gratuity in entirety. Contrastingly, in cases involving minimal misconduct, such as small-scale misappropriation by conductors in the MSRTC, the Supreme Court adopted a more lenient stance and directed the appointing authority to limit the forfeiture to 25% of the gratuity payable.

Conclusion

With the Supreme Court affirming that gratuity can be forfeited even in the absence of a criminal conviction for misconduct involving moral turpitude, the Supreme Court has empowered employers to take decisive action against ethical breaches that can undermine workplace integrity. In other words, employers can now implement stricter disciplinary measures without the fear of lengthy legal battles over gratuity claims when dealing with cases involving moral turpitude.

Additionally, this ruling encourages businesses to take proactive measures to ensure that their workplace environment upholds ethical behavior and integrity. In this respect, implementing regular training sessions that emphasise upon the importance of ethical behavior and the consequences of violations can foster a culture of accountability and awareness among employees. At the end of the day, this ruling encourages both employers and employees to uphold high ethical standards, ultimately enhancing the overall workplace culture and contributing to a healthier organisational ecosystem.

In a recent ruling involving sexual harassment, the Delhi High Court[3] had held that an employee’s gratuity cannot be forfeited even if the internal committee, established under the Sexual Harassment of Women at Workplace (Prevention, Prohibition, and Redressal) Act, 2013, finds the employee guilty of sexual harassment. In contrast, the current judgment sends a strong message about the importance of moral integrity in professional settings, making it a significant and welcome judgment in the realm of employment laws.

Having said that, employers should consider implementing clear policies outlining what constitutes ‘moral turpitude’ besides maintaining meticulous documentation to support any forfeiture decisions.

This Prism has been prepared by:

For more details, please contact [email protected].

[1] 2025 SCC OnLine SC 345
[2] (2018) 9 SCC 529
[3] Punjab National Bank vs. Sh. Niraj Gupta and Anr, (LPA 907/2024 and CAV 443/2024, CM APPL. 52155-52157/2024)