Writ@123

IN THE HIGH COURT OF JUDICATURE MADRAS AT
MADURAI BENCH
(Special Original Jurisdiction)
W.P. (MD) No. OF 2024
R.Samranjithkumar
S/o. Rajan,
Residing at Door No.34/3,
Police station opposite, Varusanadu,
Myiladumparai – 625 579, Varusanadu,
Theni District …
Petitioner
-Vs-
1. M/s.Karur Vysya Bank,

Rajapalayam Branch,
Railway feeder road, Rajapalayam,
Virudhunagar District
Rep. by its authorised officer/Chief Manager
Mr.C. Magesh
2. M/s Pommys Garments (India) Limited,

(Formerly known as Pommys Garments (India) Private
Limited,
Rep.by its Directors Mr.K.Raja & Mr.Inicoinbaraj,
No. 5/13-B, Pommys Nagar, Seithur Road,
Dhalavaipuram, Rajapalayam
Virudhunagar District 626 188.
3. K.Raja
S/o. Kumarasamy,
365A, Naidu South Street,
Jeya Sakthi Nagar,
Chettiyarpatti Ayan,
Kollaankondan Settiyarpatti.
Rajapalayam, Virudhunagar District – 626 122
4. Inico Inbaraj
S/o. R.Arul Jeganathan Christian,
No.44f, Renganadhapuram Kovil Street,
5. R.Kanika Tejawini
D/o.K.Raja,
No.365A, Jeya Sakthi Nagar,
Kommanthapuram, Chettiyarpatti,
Kollaankondan Settiyarpatti
Rajapalayam, Virudhunagar District- 626 122
6. R.Kanishk Visva,
D/o.K.Raja,
Kommanthapuram,
Chettiyarpatti, Dhalavaipuram,
Rajapalayam- 626 122 …Respondents
AFFIDAVIT OF THE PETITIONER
I, R.Samranjithkumar, Son of Rajan, aged about 53 years,

residing at Door No. 34/3, Police Station opposite, Varusanadu,
Myiladumparai – 625 579, Varusanadu, Theni District, do
hereby solemnly affirm and sincerely state as follows:
1) I am the petitioner herein and as such, I am well

acquainted with the facts of the case and I am filing this
affidavit for benign consideration of this Hon’ble Court. I have
not filed any writ petition seeking the same relief.
2) I respectfully state that I file this Writ of

Certiorarified Mandamus challenging the impugned order
dated 25.06.2024 passed by the Learned Chief Judicial
Magistrate, Tenkasi District in Criminal Miscellaneous Petition
No.93 of 2024 filed under Section 14(1) of Securitization and
Reconstruction of Financial Assets and Enforcement of Security
Interest Act, 2002 by the 1 st respondent bank and quash the
same as arbitrary and illegal and consequently direct the 1 st
respondent not to disturb the peaceful possession of the
petitioner in the schedule mentioned properties without
following due process of law.
3) I respectfully submit that, I am doing agricultural

activities in the schedule mentioned properties from the year
of 2020. I further submit that, I have entered upon lease deed
for carrying out agricultural activities in the lands comprised in
the schedule mentioned properties, with the Respondents No.3
and 4 namely K.Raja and Inico Inbaraj.
4) I respectfully submit that, for doing agricultural

activities in the schedule mentioned properties I have entered
upon two lease deeds. Accordingly, a lease deed dated
12.09.2020 was made with 3rd Respondent namely K.Raja, for a
period of seven years from 01.10.2020. The said lease deed is
made between me and 3rd Respondent, for those lands
comprised in Property No.1 as mentioned in the schedule of
properties. I further submit that another lease deed dated
12.09.2020 was made by me with 4 th Respondent namely Inico
Inbaraj, for a period of seven years from 01.10.2020. The said
lease deed is made between me and 4 th Respondent for those
lands comprised in Property No.2 and Property No.3 as
mentioned in the schedule of properties.
5) I respectfully submit that, I myself being lessee of

the properties comprised in the schedule of properties has
been doing agriculture for the past four years till now.
Moreover, as per the lease deed, I am paying Rs.10,000/- per
Hectares of land as lease amount every year to the
Respondents No.3 and 4 respectively. That being the situation,
I was shocked by the information received from the 3 rd & 4th
respondents whereby they stated that on 15.11.2024, the
schedule mentioned properties which are in my possession
now are going to be taken possession by the advocate
commissioner as per the warrant issued by the learned Chief
Judicial Magistrate, Tenkasi District.
6) I respectfully submit that I am not aware of the

transactions taken place between the 1 st Respondent Bank and
the 3rd & 4th Respondents and I have been completely kept in
dark. Moreover, the properties comprised in the Schedule of
properties are all agricultural lands and as per Section 31 of
SARFAESI Act, 2002, the provisions of the said act will not
apply for any security interest created in agricultural land. That
being so, the 1st Respondent bank has unlawfully and with
misrepresentation of facts had obtained the impugned order
dated 25.06.2024 from the learned Chief Judicial Magistrate,
Tenkasi District by filing application under Section 14 of
Securitization and Reconstruction of Financial Assets and
Enforcement of Security Interest Act, 2002 seeking order for
assistance of taking physical possession by appointing an
Advocate commissioner. I further submit that the above 1 st
Respondent Bank’s act is unlawful and illegal, particularly the
1st Respondent Bank had suppressed the fact that the lands
comprised in the schedule of properties are agricultural lands
before the learned Chief Judicial Magistrate, Tenkasi District
and hence by way of filing this Writ of Certiorarified Mandamus
the impugned order dated 25.06.2024 passed in Criminal
Miscellaneous Petition No.93 of 2024 is challenged for the
following among other grounds.
GROUNDS
a. At the outset itself, the impugned order dated
25.06.2024 passed by the learned Chief Judicial
Magistrate, Tenkasi District is liable to be set aside as it
suffers from infirmity.
b. The Petitioner as a lessee has been doing agriculture in
the lands comprised in schedule mentioned properties
from the year of 2020 and neither the 1 st Respondent
bank nor the 3rd & 4th Respondents who are the lessor,
have not intimated to the petitioner about the
transactions taken place between them. That being so,
the petitioner cannot be removed from the possession all
of a sudden in an arbitrary manner.
c.The petitioner being the lessee and in possession of lands

from the year of 2020 was not approached till date by the
1st Respondent bank and no notice or any intimation was
given to the petitioner which clearly shows the wilful
negligence and ill motive of the 1st Respondent bank.
d. The lands comprised in the schedule mentioned

properties are all agricultural lands and the 1st
Respondent bank evenafter knowing the same has
proceeded under SARFAESI Act, 2002 which is illegal and
not maintainable.
e. Section 31 (h) of SARFAESI Act, 2002 clearly mentions

about the non applicability of the provisions of the Act for
any security interest created in agricultural land. That
being so the proceedings taken by the 1st Respondent
Bank is illegal and it is in violation of provisions of
SARFAESI Act, 2002 and hence the impugned order is
liable to be set aside.
f.The order dated 25.06.2024 passed in Criminal

Miscellaneous Petition No.93 of 2024 on the file of
learned Chief Judicial Magistrate, Tenkasi District is liable
to be set aside as it obtained by misrepresentation of
facts or false statement.
g. The petitioner is neither a guarantor nor a borrower and

only a lessee who is in possession of the land and doing
agricultural works as per the lease deed. That being so all
of the sudden, the 1st Respondent bank trying to take
over the possession of the said lands comprised in the
schedule of properties in an illegal manner based on the
impugned order dated 25.06.2024 is Ex facie illegal and
hence the impugned order is liable to be set aside.
h. The impugned order dated 25.06.2024 is passed by

believing only available records filed by the 1 st
Respondent bank which are all misrepresentation of facts
and application not maintainable as per the provisions of
the SARFAESI Act, 2002 and hence the impugned order is
liable to be set aside.
i. At any event, the impugned order dated 25.06.2024 is

liable to set aside as it is passed without jurisdiction and
it is in the violation of due process of law.
7) I respectfully submit that I am in possession of

photocopy of the original impugned order dated 25.06.2024
passed by the Learned Chief Judicial Magistrate, Tenkasi
District in Criminal Miscellaneous Petition No.93 of 2024 and I
am not able to produce the original of the impugned order and
hence I am filing this writ petition with the photocopy of the
impugned order dated 25.06.2024 and therefore I may be
permitted to file this writ petition by dispense with the
production of the original impugned order dated 25.06.2024
passed by the Learned Chief Judicial Magistrate, Tenkasi
District in Criminal Miscellaneous Petition No.93 of 2024.
8) I respectfully submit that, since the 1 st respondent

bank is proceeding to take possession of the schedule
mentioned properties on 15.11.2024 in pursuant to the
impugned order which is illegal and hence it is just and
necessary to stay all further proceedings in pursuant to the
impugned order dated 25.06.2024 passed by the Learned
Chief Judicial Magistrate, Tenkasi District in Criminal
Miscellaneous Petition No.93 of 2024 pending disposal of the
writ petition.
Therefore it is prayed that this Hon’ble Court may be

pleased to dispense with the production of the original
Miscellaneous Petition No.93 of 2024 by accepting the photo
copy of the same and thus render justice.
Therefore, it is prayed that this Hon’ble Court may be

pleased to STAY all further proceedings in pursuant to the
Miscellaneous Petition No.93 of 2024 pending disposal of the
writ petition and thus render justice.
Therefore, it is prayed that this Hon’ble Court may be

pleased to issue a Writ, Order or Direction more particularly in
the nature of WRIT OF CERTIORARIFIED MANDAMUS
calling for the records in pursuant to the impugned order dated
25.06.2024 passed by the Learned Chief Judicial Magistrate,
Tenkasi District in Criminal Miscellaneous Petition No.93 of
2024 filed under Section 14(1) of Securitization and
Reconstruction of Financial Assets and Enforcement of Security
Interest Act, 2002 by the 1st respondent bank and quash the
same as arbitrary and illegal and consequently direct the 1 st
respondent not to disturb the peaceful possession of the
petitioner in the schedule mentioned properties without
following due process of law and pass such further or other
orders as this Hon'ble Court may deem fit and proper in the
circumstances of the case and thus render justice.
Solemnly affirmed at Rajapalayam

on this the day of November, 2024
and when the contents of the BEFORE
ME
affidavit explained to the
Deponent in Tamil he appeared
to have understood the same
and signed his name in my presence.
ADVOCATE
MADURAI BENCH
W.P. (MD) No. OF 2024
R.Samranjithkumar
S/o. Rajan,
Theni District …
Petitioner
-Vs-

Rajapalayam Branch,
Mr.C. Magesh

Limited,
3. K.Raja
S/o. Kumarasamy,
Jeya Sakthi Nagar,
4. Inico Inbaraj
D/o.K.Raja,
6. R.Kanishk Visva,
D/o.K.Raja,
Kommanthapuram,
SYNOPSIS
A. The petitioner is doing agriculture work in the schedule

mentioned properties from 2020 for which he has made
lease deeds with 3rd & 4th respondents.
B. The petitioner was shocked upon information from 3 rd &

4th respondents that the lands comprised in the schedule
mentioned properties are going to be taken possession
by the 1st respondent bank as per the order dated
25.06.2024 passed by the learned Chief Judicial
Magistrate, Tenkasi District in Criminal Miscellaneous
Petition No.93/2024.
C. The petitioner does not know about the transactions

between the 1st Respondent Bank and the 3rd & 4th
respondents and he is only a lessee doing agricultural
work in the said lands.
D. Also, the lands comprised in the schedule mentioned

properties are all agricultural lands and SARFAESI
Act,2002 and its provisions will not apply for security
made in agriculture land.
E. The 1st respondent bank has suppressed the above said

fact and has obtained the order of learned Chief Judicial
Magistrate which is illegal and in pursuant to the order
the 1st respondent is proceeding for taking physical
possession of the lands in which the petitioner is doing
agricultural activities.
F. The petitioner is in possession of the lands and moreover

he is only a lessee who cannot be made to suffer loss by
the illegal act of 1st respondent bank and hence
challenging the same Writ petition has been filed.
DATES AND EVENTS
12.09.202
Lease Deed made with 3rd respondent
0
12.09.202 Lease Deed made with 4th respondent
0
Order passed by learned Chief Judicial
25.06.202
Magistrate in Criminal Miscellaneous Petition
4
No.93/2024
15.11.202
Date of possession
4
Dated at Madurai on this the day of November 2024
Counsel for Petitioner

MADURAI BENCH
W.P. (MD) No. OF 2024
R.Samranjithkumar
S/o. Rajan,
Theni District …
Petitioner
-Vs-
M/s.Karur Vysya Bank,

Rajapalayam Branch,
Mr.C. Magesh
And 5 others ...Respondents
BATTA
Paid Rs.180/-
Address for the respondents:

Rajapalayam Branch,
Mr.C. Magesh

Limited,
3. K.Raja
S/o. Kumarasamy,
Jeya Sakthi Nagar,
4. Inico Inbaraj
D/o.K.Raja,
6. R.Kanishk Visva,
D/o.K.Raja,
Kommanthapuram,
IN THE HIGH COURT OF JUDICATURE AT MADRAS

MADURAI BENCH
W.P.(MD)No. of 2024
R.Samranjithkumar
S/o. Rajan,
Theni District …
Petitioner
-Vs-
M/s.Karur Vysya Bank,

Rajapalayam Branch,
Mr.C. Magesh
And 5 others ...Respondents
INDEX TO THE PAPER BOOK
Sl.N Pg
Date Description of Documents
o No
1 Synopsis & Date and Events
2 Court Fee
3 Coding Sheet
4 Writ Petition
5 Petition for stay
6 Common Affidavit
25.06.202
7 Impugned order
4
TYPED SET OF PAPERS

Lease Deed made with 3rd
8 12.09.202
0 respondent
9 12.09.202 Lease Deed made with 4th

0 respondent
10 --- ‘A’ register details
11 --- Photo of the lands
25.06.202
12 Impugned order
4
13 Vakalat
14 Batta
Certified to be true copies of respective originals.

TENKASI District
HIGH COURT :: MADRAS
MADURAI BENCH
W.P(MD).No. of
2024
PAPER BOOK OF
THE PETITIONER
M/s. ARAN LEGAL CONSULTANCY

G.ARAVINTHAN
MS.No.674/2006
S.R.SATHAN BOOPATHY
Ms.No.1288/2012

99402 36948
TENKASI District
MADURAI BENCH
W.P(MD).No. of
2024
WRIT PETITION

G.ARAVINTHAN
MS.No.674/2006
S.R.SATHAN BOOPATHY
Ms.No.1288/2012

99402 36948
(Memorandum of Writ Petition presented under
Article 226 of Constitution of India)
IN THE HIGH COURT OF JUDICATURE OF MADRAS
AT MADURAI BENCH
W.P(MD).No. OF 2024
R.Samranjithkumar
S/o. Rajan,
Theni District …
Petitioner
-Vs-

Rajapalayam Branch,
Mr.C. Magesh

Limited,
3. K.Raja
S/o. Kumarasamy,
Jeya Sakthi Nagar,
4. Inico Inbaraj
D/o.K.Raja,
6. R.Kanishk Visva,
D/o.K.Raja,
Kommanthapuram,
WRIT PETITION
I. The address of the petitioner for the service of the notice

and process of this Honorable Court is that of his counsel
M/s.ARAN LEGAL CONSULTANCY - G.ARAVINTHAN &
S.R.SATHAN BOOPATHY at No.119, Lawyer Chambers,
High Court Buildings, Madurai - 625 023 and also at RH-
59, Meenakshi Avenue, Kalai Nagar I Street, Madurai –
625 017.
II. The address of the respondents for the service of notice

and process of this Honorable Court is the same as stated
above.
III. For the reasons stated in the accompanying affidavit, it is

prayed that this Hon’ble Court may be pleased to issue a
Writ, Order or Direction more particularly in the nature of
WRIT OF CERTIORARIFIED MANDAMUS calling for the
records in pursuant to the impugned order dated
25.06.2024 passed by the Learned Chief Judicial
Magistrate, Tenkasi District in Criminal Miscellaneous
Petition No.93 of 2024 filed under Section 14(1) of
Securitization and Reconstruction of Financial Assets and
Enforcement of Security Interest Act, 2002 by the 1st
respondent bank and quash the same as arbitrary and
illegal and consequently direct the 1st respondent not to
disturb the peaceful possession of the petitioner in the
schedule mentioned properties without following due
process of law and pass such further or other orders as
this Hon'ble Court may deem fit and proper in the
circumstances of the case and thus render justice.
Dated at Madurai this the day of November 2024
SCHEDULE OF PROPERTY
Tirunelveli District (Now Tenkasi District), Sivagiri Sub

Registration Office, Sivagiri Part Il Village, Survey Nos.88/2 and
96/1 and building constructed in Survey No.86 bearing D.No.27,
2nd ward Sivagiri Village. Four boundaries: Survey No.88/2 -
0.82.50 Hectrs.
North by - Land in Survey No.86
East by - Land in Survey Nos.88/3A and 88/3C
South by - Land in Survey No.89
Westby - Land in Survey No.88/1
Survey No.96/1-0.88.0 Hectrs
South - Land in Survey Nos.96/2, 96/3 and 96/4
West - Land in Survey No.86, 96/2
North - Land in Survey No.97

East - Land in Survey No.99
Survey No.86- 2.61.00 Hectrs
South- Land in survey Nos.87, 88/1, 88/2, 88/3A, 8613B

and 96/2
West - Land in Survey No.84, 85/4A and 85/4B
North - Land in Survey No. 62 and 63
East - Land in Survey No.97 and 96/1
Property No.2
Tirunelveli District (Now Tenkasi District), Tirunelveli

Registration District, Sivagiri Sub Registration Office, Sivagiri Part
Il Village, Land in Survey Nos.61/1 land measuring 0.45.50
Hectrs. Survey No.62 land measuring 2.20.0 hectrs and undivided
half share in the well situated in survey No.86 in Sivagiri part II
Village. Four boundaries:
1. Survey No.61/1 -0.45.50 Hectrs.
South - Punja land in survey Nos.61/2A, 2B, 2C and 2D
West - Punja Land in Survey No.66
North - Punja Land in Survey No.66
East - Punja Land in Survey No.59
2. Survey No.62-2.28.00 Hectrs
South - Land in survey Nos.86 and 97
West - Land in Survey No.63 and 86
North - Land in Survey No.60 and 61
Property No.3
Tirunelveli District, Sivagiri Sub Registration Office, Sivagiri
Taluk, Sivagiri Part II Village, Vacant Site in Survey Nos.61/2A
land measuring 0.70.50 Hectrs. Survey No.61/2D land measuring
0.27.0 hectrs, Survey No.85/4A land measuring 0.23.50 Hectrs
and 85/4B land measuring 0.23.50 hectrs. Four boundaries:
1. Survey No.61/2A, 0.70.50 Hectrs
South - Land in survey Nos.62
West - Land in Survey No.63
North - Land in Survey No.61/I and 66
East - Land in Survey No.61/2B
2. Survey No.61/2D, 027.00 Hectrs
South - Land in survey Nos.62
West - Land in Survey No.61/2C
North - Land in Survey No.60 and 61/1
East - Land in Survey No.61/2E
3. Survey No.85/4A, 0.23.50 Hectrs
South- Land in survey Nos.84
West - Land in Survey No.85/3
North- Land in Survey No. 85/4B
5. Survey No.85/4B, 0.23.50 Hectrs
South - Land in survey Nos.85/4A
West - Land in Survey No. 85/3
North - Land in Survey No.63 and 65,
East - Land in Survey No. 86

(Memorandum of Writ Miscellaneous Petition presented
under Article 226 of Constitution of India)
AT MADURAI BENCH
W.M.P(MD)No. of 2024
in
W.P(MD).No. of 2024
R.Samranjithkumar
S/o. Rajan,
Theni District
…Petitioner/Petitioner
-Vs-

Rajapalayam Branch,
Mr.C. Magesh

Limited,
3. K.Raja
S/o. Kumarasamy,
Jeya Sakthi Nagar,
4. Inico Inbaraj
D/o.K.Raja,
6. R.Kanishk Visva,
D/o.K.Raja,
Kommanthapuram,
Rajapalayam- 626 122 …Respondents/Respondents
PETITION FOR STAY
For the reasons stated in the accompanying affidavit, it is

it is prayed that this Hon’ble Court may be pleased to STAY all
further proceedings in pursuant to the impugned order dated
2024 pending disposal of the writ petition and thus render
justice.

(Memorandum of Writ Miscellaneous Petition presented
under Article 226 of Constitution of India)
AT MADURAI BENCH
W.M.P(MD)No. of 2024
in
W.P(MD).No. of 2024
R.Samranjithkumar
S/o. Rajan,
Theni District
…Petitioner/Petitioner
-Vs-

Rajapalayam Branch,
Mr.C. Magesh

Limited,
3. K.Raja
S/o. Kumarasamy,
Jeya Sakthi Nagar,
4. Inico Inbaraj
D/o.K.Raja,
6. R.Kanishk Visva,
D/o.K.Raja,
Kommanthapuram,
Rajapalayam- 626 122 …Respondents/Respondents
PETITION FOR DISPENSE WITH
For the reasons stated in the accompanying affidavit, it is

prayed that this Hon’ble Court may be pleased to dispense
with the production of the original impugned order dated
2024 by accepting the photo copy of the same and thus
render justice.

TENKASI District
MADURAI BENCH
W.M.P(MD) No. of 2024

in
W.P(MD).No. of 2024
PETITION FOR DISPENSE WITH

G.ARAVINTHAN
MS.No.674/2006
S.R.SATHAN BOOPATHY
Ms.No.1288/2012

99402 36948
TENKASI District
MADURAI BENCH
W.M.P(MD) No. of 2024

in
W.P(MD).No. of 2024
PETITION FOR STAY

G.ARAVINTHAN
MS.No.674/2006
S.R.SATHAN BOOPATHY
Ms.No.1288/2012

99402 36948

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IN THE HIGH COURT OF JUDICATURE MADRAS AT

W.P. (MD) No. OF 2024

1. M/s.Karur Vysya Bank,

2. M/s Pommys Garments (India) Limited,

AFFIDAVIT OF THE PETITIONER

I, R.Samranjithkumar, Son of Rajan, aged about 53 years,

1) I am the petitioner herein and as such, I am well

2) I respectfully state that I file this Writ of

3) I respectfully submit that, I am doing agricultural

4) I respectfully submit that, for doing agricultural

5) I respectfully submit that, I myself being lessee of

6) I respectfully submit that I am not aware of the

c.The petitioner being the lessee and in possession of lands

d. The lands comprised in the schedule mentioned

e. Section 31 (h) of SARFAESI Act, 2002 clearly mentions

f.The order dated 25.06.2024 passed in Criminal

g. The petitioner is neither a guarantor nor a borrower and

h. The impugned order dated 25.06.2024 is passed by

i. At any event, the impugned order dated 25.06.2024 is

7) I respectfully submit that I am in possession of

8) I respectfully submit that, since the 1 st respondent

Therefore it is prayed that this Hon’ble Court may be

Therefore, it is prayed that this Hon’ble Court may be

Therefore, it is prayed that this Hon’ble Court may be

Solemnly affirmed at Rajapalayam

W.P. (MD) No. OF 2024

1. M/s.Karur Vysya Bank,

2. M/s Pommys Garments (India) Limited,

A. The petitioner is doing agriculture work in the schedule

B. The petitioner was shocked upon information from 3 rd &

C. The petitioner does not know about the transactions

D. Also, the lands comprised in the schedule mentioned

E. The 1st respondent bank has suppressed the above said

F. The petitioner is in possession of the lands and moreover

DATES AND EVENTS

Dated at Madurai on this the day of November 2024

Counsel for Petitioner

IN THE HIGH COURT OF JUDICATURE MADRAS AT

W.P. (MD) No. OF 2024

M/s.Karur Vysya Bank,

1. M/s.Karur Vysya Bank,

2. M/s Pommys Garments (India) Limited,

Dated at Madurai on this the day of November 2024

Counsel for Petitioner

IN THE HIGH COURT OF JUDICATURE AT MADRAS

M/s.Karur Vysya Bank,

TYPED SET OF PAPERS

9 12.09.202 Lease Deed made with 4th

Certified to be true copies of respective originals.

Dated at Madurai on this the day of November 2024

Counsel for Petitioner

M/s. ARAN LEGAL CONSULTANCY

Counsel for Petitioner

M/s. ARAN LEGAL CONSULTANCY

Counsel for Petitioner

1. M/s.Karur Vysya Bank,

2. M/s Pommys Garments (India) Limited,

I. The address of the petitioner for the service of the notice

II. The address of the respondents for the service of notice

III. For the reasons stated in the accompanying affidavit, it is