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Issues: Whether the remedies under sections 31 and 32G of the State Financial Corporations Act, 1951 are mutually exclusive, and whether recovery under section 32G can be pursued against a surety after proceedings under section 31 did not determine the surety's liability.
Analysis: The Act provides distinct modes for recovery of dues by a financial corporation. Section 31 enables recourse to the District Judge for specified reliefs, while section 32G permits recovery of amounts due as arrears of land revenue through a certificate issued by the State Government or its authorised authority. The expressions used in section 32G, particularly "without prejudice to any other mode of recovery", show that the remedy is additional to, and not in substitution for, other remedies under the Act. The earlier proceedings under section 31 did not adjudicate the surety's liability on merits, because at the relevant time section 31 did not empower enforcement against sureties. In such circumstances, invocation of section 32G against the surety was not barred merely because the corporation had earlier pursued section 31 against the industrial concern. The satisfaction of the State Government or specified authority about the amount due must still be reached in accordance with a fair summary procedure, but the prior section 31 proceedings do not extinguish the statutory power under section 32G.
Conclusion: The remedies under sections 31 and 32G are not mutually exclusive, and the corporation was entitled to proceed under section 32G against the surety.
Ratio Decidendi: Where a statute expressly provides a recovery mechanism "without prejudice to any other mode of recovery", the later statutory recovery procedure remains available notwithstanding prior recourse to another remedy, provided the earlier proceeding did not finally determine the same liability.