Section 22 SICA protection applies only to liabilities covered by a sanctioned rehabilitation scheme, not every pending recovery claim.

Section 22 of the Sick Industrial Companies (Special Provisions) Act, 1985 bars coercive recovery only where the liability is actually covered by a sanctioned rehabilitation scheme. Mere pendency of rehabilitation proceedings does not suspend all recovery action, and the protection does not extend to every outstanding debt merely because an enquiry is pending. On the stated facts, the decree debt was not shown to have been included in the sanctioned scheme, so section 22 did not prevent recovery and the recovery notice was not liable to be quashed on that ground.

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Issues: Whether the bar under section 22 of the Sick Industrial Companies (Special Provisions) Act, 1985 applies to recovery of a decree debt when the amount is not shown to have been included in the sanctioned rehabilitation scheme.

Analysis: The statutory protection under section 22 is intended to prevent coercive action that would impede implementation of a sanctioned scheme for revival of a sick industrial company. Mere pendency of an enquiry for rehabilitation does not, by itself, suspend all recovery proceedings. The bar operates in relation to liabilities or amounts actually reckoned or included in the sanctioned scheme, and not to every outstanding dues merely because proceedings under the Act are pending.

Conclusion: Section 22 did not protect the appellant against recovery of the decree debt, since the amount was not shown to be covered by the sanctioned scheme. The recovery notice was therefore not liable to be quashed on that ground.

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