SARFAESI exclusivity bars company court interference with secured creditor auction proceedings and directs remedies to statutory forums.

The SARFAESI Act provides a special, self-contained mechanism for enforcing security interests through possession, sale by auction, and statutory remedies before the DRT and DRAT. Because sections 34 and 35 bar inconsistent civil jurisdiction and give the Act overriding effect, the company court cannot stay or interfere with auction proceedings initiated by a secured creditor. Relief against measures taken under section 13(4) must be pursued only within the SARFAESI framework, and proceedings in company court are not maintainable for that purpose.

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Issues: Whether the company court had jurisdiction to stay or interfere with a secured creditor's auction proceedings initiated under the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002.

Analysis: The secured creditor had proceeded under the SARFAESI Act by taking possession of the secured assets and proposing sale by public auction. The Act was treated as a special enactment providing a complete mechanism for enforcement of security interest, including measures under section 13(4), an appeal to the Debts Recovery Tribunal under section 17(1), and a further appeal under section 18(1). Sections 34 and 35 were applied to hold that civil court jurisdiction is barred in respect of matters that the DRT or DRAT is empowered to determine and that the SARFAESI Act overrides inconsistent laws. On that basis, the company court could not grant an injunction or stay against the auction proceedings, and the proper remedy lay only under the SARFAESI framework.

Conclusion: The application before the company court was not maintainable, and the challenge to the auction could not be entertained in company proceedings.

Ratio Decidendi: Where the SARFAESI Act provides a special, self-contained and overriding statutory mechanism for enforcement of security interest, the company court's jurisdiction is excluded and relief against measures taken under section 13(4) must be sought only before the forums created by that Act.

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