Undervaluation and agricultural-land exemption claims failed where reserve price and land use were supported by evidence under SARFAESI.

Alleged undervaluation did not vitiate the sale of secured assets where the reserve price was fixed after considering multiple valuations, contemporaneous comparative figures, and government fair value records, and the borrowers' own lower sale of the mortgaged properties undermined the challenge. The plea that the property was agricultural land also failed, because agricultural character under Section 31(i) of the SARFAESI Act depends on the land's nature, actual use, and purpose, and revenue description alone is not conclusive. The borrowers had treated the property as vacant land and proved no agricultural activity or income, so the sale action was upheld.

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Issues: (i) Whether alleged undervaluation vitiated the sale of the secured assets; (ii) Whether the secured asset brought to sale was agricultural land so as to attract the exemption under Section 31(i) of the SARFAESI Act, 2002.

Issue (i): Whether alleged undervaluation vitiated the sale of the secured assets.

Analysis: The reserve price was fixed after considering multiple valuations, including earlier borrower-side values, a subsequent panel valuer's assessment, and the government fair value records. The Bank gave reasons for preferring the higher and more contemporaneous comparative figures and for discounting an earlier valuation found to be excessive. The borrowers' own sale of the mortgaged properties for a much lower amount also undermined the plea of gross undervaluation.

Conclusion: The alleged undervaluation did not vitiate the sale and this issue was decided against the petitioners.

Issue (ii): Whether the secured asset brought to sale was agricultural land so as to attract the exemption under Section 31(i) of the SARFAESI Act, 2002.

Analysis: The character of land for the purpose of the exemption depends on the nature of the land, the use to which it was put, and the purpose for which it was set apart, and revenue descriptions alone are not conclusive. Applying that approach, the Court found that the borrowers had consistently described the property as vacant land and never asserted agricultural character before the Bank; the companies did not show agricultural activity, agricultural income, or an agricultural object; and the plea was raised only after sale proceedings commenced. The exemption in Section 31(i) is intended to protect genuine agricultural land held and used for agricultural purposes, not corporate security offered for commercial borrowing.

Conclusion: The property was not proved to be agricultural land within the meaning of Section 31(i), and the issue was decided against the petitioners.

Final Conclusion: The writ petition failed on merits because neither undervaluation nor the agricultural-land plea displaced the Bank's sale action under the SARFAESI regime.

Ratio Decidendi: For Section 31(i) of the SARFAESI Act, 2002, agricultural character is a factual determination based on the land's nature, actual use, and purpose, and revenue description by itself is not conclusive; a sale will not be invalidated merely because a higher earlier valuation exists if the secured creditor has given rational reasons for fixing the reserve price.

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