Finality under SARFAESI section 14 bars criminal revision, while constitutional review needs a clear case of illegality.

An order passed under section 14 of the SARFAESI Act, after compliance with sections 13(2) and 13(4), was held not to be amenable to revisional jurisdiction under section 397 CrPC because section 14(3) gives finality to the act done under that provision and the proceeding is not a criminal proceeding for section 397 purposes. The Court also noted that a statutory finality clause does not exclude constitutional review under Articles 226 and 227, but no patent error or illegality in the Magistrate's order was shown. Revision was therefore not maintainable, and no ground for writ interference was made out.

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Issues: Whether an order passed under section 14 of the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 is amenable to revisional jurisdiction under section 397 of the Code of Criminal Procedure, 1973 and whether interference under Article 226 of the Constitution of India was warranted.

Analysis: The order under section 14 was passed after the secured creditor had followed the statutory steps under sections 13(2) and 13(4) of the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002. The Court noted that section 14(3) attaches finality to the act done under section 14 and that such proceedings are not criminal proceedings for the purpose of section 397 of the Code of Criminal Procedure, 1973. Reliance was placed on the settled principle that a statutory finality clause does not bar constitutional jurisdiction under Articles 226 and 227, but that principle did not assist the petitioner because the challenge was pursued through revision, not on any ground showing patent error or illegality in the Magistrate's order.

Conclusion: The revision under section 397 of the Code of Criminal Procedure, 1973 was not maintainable against the order under section 14 of the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002, and no ground for interference under Article 226 of the Constitution of India was made out.

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