Section 21-A bars reopening bank loans for excessive interest, including pending suits and appeals, and covers agricultural and commercial advances.

Section 21-A of the Banking Regulation Act, 1949 bars courts from reopening bank loan transactions on the ground of excessive interest, and this prohibition applies to transactions entered into before its commencement as well as to suits and appeals pending when it came into force. The debtor has no vested substantive right to reopening under Section 3 of the Usurious Loans Act, 1918, because any such claim is only contingent relief subject to later legislative change. As an appeal is a continuation of the suit, the statutory bar operates throughout pending proceedings. The provision applies equally to agricultural and commercial advances, and the contrary view allowing reopening after Section 21-A was overruled.

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Issues: Whether Section 21-A of the Banking Regulation Act, 1949 applies to loan transactions entered into before its commencement, whether it governs suits and appeals pending on the date it came into force, and whether it applies equally to agricultural and commercial advances.

Analysis: Section 21-A contains a prohibitory mandate that a transaction between a banking company and its debtor shall not be reopened by any Court on the ground that the interest is excessive. The power under Section 3 of the Usurious Loans Act, 1918 to reopen transactions depends upon judicial enquiry and does not create a vested right in the debtor merely because a loan was advanced or a suit was filed. The right asserted by the debtor is only a claim to seek relief, not an accrued substantive right immune from later legislative change. Since an appeal is a continuation of the suit, the statutory bar operates at every stage of the proceeding while the matter remains pending. The provision was enacted to remove the conflict between bank lending policy regulated by the Reserve Bank of India and the operation of local usury laws, and it applies to proceedings involving agricultural as well as commercial loans.

Conclusion: Section 21-A applies to prior transactions and to pending suits and appeals, and it bars reopening of bank transactions under the Usurious Loans Act, 1918 regardless of whether the advance was agricultural or commercial.

Final Conclusion: The earlier view that bank debt transactions could still be reopened under usury laws after Section 21-A came into force was overruled, and the connected bank appeals succeeded while the debtor's appeal failed.

Ratio Decidendi: A statutory prohibition on reopening bank transactions under Section 21-A of the Banking Regulation Act, 1949 governs all pending stages of litigation and overrides any merely contingent claim to relief under the Usurious Loans Act, 1918, because no vested right to reopening exists in favour of the debtor.

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