Sunday, April 7, 2019

Section 35AA and the IBC: Is the Recent Supreme Court judgment a dampener?



For a legal novice like me, the Supreme Court judgments are opportunities to add to my vocabulary of English. Three that I came across recently   for the first time are “manifest arbitrariness”, “speaking statutes” and “de Hors”.

Fortunately, as with all the SC judgments that I have come across, my lack of lexicon does not hinder my appreciation of the final “Orders”.

So I am clear that in a recent Order the Court judged that the RBI did not have the “authority” to set out a “procedure” for bringing delinquent accounts in excess of Rs 2000 cr. under the ambit of the IBC. This procedure was highlighted in an RBI Circular dated 12FEB2018. The RBI has claimed its powers to issue this Circular as coming under Section 35A of the Banking Regulation Act (BR Act). The Supreme Court, pointed out that a sub section under this Section (Section 35AA) , actually stipulates that only the Central Government could direct the RBI to refer matters in respect of specific accounts to the  taken up under the IBC. The Court was clear that that the RBI could not under this section pass “general” directives.  All cases referred to the IBC based on this Circular was, therefore, null and void (“non est.” another new word for me)     

As with any judgment there would be opinions galore and I am not about to share my views on it. My take is on three issues

ISSUE 1:
What of the cases referred by the Banks under the IBC, not on the basis of the RBI Circular, but on their own volition? To me it seems that they are not touched- and so we hard working IPs are not yet out of a vocation! Its business as usual …

ISSUE 2:
 What was the motivation for the Centre to bring in Section 35AA in the first instance? The Code is driven by two major objectives of:

 (1) Resolving defaults primarily through finding resolutions for continuing operations- with liquidation being a last resort
 And
(2) Ensuring this is speedily effected within a reasonable time frame.

The Counsel for the RBI informed the Court that when the Centre inserted (through an Ordinance no less!) the Sub Section, they had no intention of curbing the powers of the RBI. The Counsel quoted verbatim the Finance Minister on this point. The Court, however, was not impressed – that’s where I learnt about speaking statutes.

The large delinquent accounts have large Corporates behind them. Large Corporates have tenuous and powerful networks to protect their interests. If the 12FEB18 Circular of the RBI was found to be valid by the Supreme Court , each and every account would have to come before the IBC , if no resolution is found within 180 days of the first default. And we all know what happens thereafter- the existing Promoters are not permitted to put up a Resolution Plan. Mercifully the Court Order has released them from this Damocles sword.  They can now work through the corridors of the bureaucracy and the political hierarchy and prevent any reference for years to come. This affects the prospects of Banks, who are repositories of public deposits. The Counsel for the RBI stressed before the Court that the BR Act was to empower the RBI to pass directives in the (1) public interest, (2) in the interest of banking policy and (3) in the interest of depositors. The Court whilst defending the constitutional validity of the BR Act and the Circular was concerned with the violation of the specific Sub Section 35AA. 
  
ISSUE 3:
180 days… As any Banker would vouch, it takes a few hours to arrive at what is wrong with an Account. Add a few more days, and a serious banker can come up with the causes of a default and the possible remedial measures. I found it so painful to read of the SBI and the REC, two financial behemoths stating before a Parliamentary Committee that 180 days is just not enough to come up with a solution. Instead of being strong proponents of a shorter time bound resolution, it is sad to note these Institutions seeking more time. They undermine the very purpose of the IBC. Currently in the JET Airways case, we see the same SBI proactively attempting at a quick resolution, knowing that any period as long as 180 days would only worsen the situation. I do hope the RBI and the Ministry of Finance and the IBBI would not give credence to these statements of the two Institutions.

+++ 06APR19   

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