Limited tribunal jurisdiction under SARFAESI and debt recovery law does not permit general liberty to sue a bank independently.

Tribunals under the SARFAESI Act and the Recovery of Debts Due to Banks and Financial Institutions Act exercise limited, special jurisdiction confined to disputes arising under those statutes and to measures taken by the secured creditor. Section 19(25) of the Recovery of Debts Due to Banks and Financial Institutions Act allows only orders necessary to give effect to the Tribunal's directions, prevent abuse of process, or secure the ends of justice; it does not authorise a general liberty to commence independent proceedings against a bank. A tribunal created by special statute cannot extend its powers beyond express or necessarily implied authority.

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Issues: Whether the Appellate Tribunal had jurisdiction under the SARFAESI Act and the Recovery of Debts Due to Banks and Financial Institutions Act to grant liberty to the auction purchaser to initiate action against the bank for any alleged omission, and whether the High Court was right in declining to interfere with that direction.

Analysis: The statutory scheme under the SARFAESI Act and the Recovery of Debts Due to Banks and Financial Institutions Act confers on the Tribunal and Appellate Tribunal a limited and special jurisdiction to adjudicate disputes arising under the enactments, to examine the validity of measures taken by the secured creditor, and, where warranted, to grant compensation and costs. The Tribunal is not a court of general jurisdiction and cannot travel beyond the powers expressly or necessarily impliedly conferred by statute. The power under section 19(25) of the Recovery of Debts Due to Banks and Financial Institutions Act permits such orders as are necessary to give effect to its orders, prevent abuse of process, or secure the ends of justice, but does not authorise a general liberty to file an independent action against a bank. Since the bank was not a party to the compromise between the borrower and the auction purchaser, the grant of such liberty had no statutory foundation.

Conclusion: The direction granting liberty to the auction purchaser to proceed against the bank was beyond jurisdiction and was liable to be deleted; the High Court ought to have interfered with that part of the order.

Final Conclusion: The appeal succeeded to the extent that the impugned observation conferring liberty on the auction purchaser was set aside, while the remainder of the tribunal's arrangement was left undisturbed.

Ratio Decidendi: A tribunal created under a special statute cannot grant a general liberty to initiate independent proceedings unless such power is expressly conferred by the statute or necessarily implied for effective exercise of its limited jurisdiction.

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