Restructuring agreements and statutory recovery rights remain enforceable where additional funding is discretionary, not obligatory.

A restructuring agreement and related sanction documents were treated as controlling the parties' rights, so a later RBI circular could not extinguish contractual claims already crystallised under the earlier arrangement. The restructuring materials were read as approving only the additional working capital expressly sanctioned; any further funding was discretionary, not mandatory, and consultant projections did not create a binding promise. Relief to stop lenders from pursuing recovery, including proceedings under the Insolvency and Bankruptcy Code and SARFAESI, was not available because repayment obligations remained enforceable and statutory remedies could not be blocked through writ-based specific performance.

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Issues: (i) Whether the later RBI circular dated 12.02.2018 extinguished the petitioner's claim for enforcement of the earlier restructuring framework and the Joint Lenders Restructuring Agreement; (ii) Whether the lenders were contractually bound under the restructuring documents to provide additional working capital beyond the sum expressly approved; (iii) Whether the Court could restrain the lenders from pursuing recovery remedies, including proceedings under the Insolvency and Bankruptcy Code and the SARFAESI Act.

Issue (i): Whether the later RBI circular dated 12.02.2018 extinguished the petitioner's claim for enforcement of the earlier restructuring framework and the Joint Lenders Restructuring Agreement.

Analysis: The revised RBI framework did withdraw earlier circulars, but the restructuring had already been translated into binding agreements between the parties. A later regulatory change could not be read as terminating contractual rights and obligations already crystallised under the Joint Lenders Restructuring Agreement. The petitioner's claim for enforcement of the earlier restructuring arrangement therefore could not be rejected merely because the later framework came into force.

Conclusion: The later circular did not extinguish the petitioner's contractual claim founded on the existing restructuring agreement.

Issue (ii): Whether the lenders were contractually bound under the restructuring documents to provide additional working capital beyond the sum expressly approved.

Analysis: The restructuring package, the sanction letters and the schedules to the Joint Lenders Restructuring Agreement showed only the additional working capital expressly approved in the restructuring package. The clause dealing with further working capital made any additional sanction discretionary, not obligatory. The projected financial tables in the consultant's report did not amount to a binding promise of further funding. The Court also found that the petitioner's subsequent reliance on non-disbursal could not override the express contractual terms.

Conclusion: The lenders were not under a contractual obligation to provide further additional working capital beyond what was expressly approved.

Issue (iii): Whether the Court could restrain the lenders from pursuing recovery remedies, including proceedings under the Insolvency and Bankruptcy Code and the SARFAESI Act.

Analysis: The petitioner's request would effectively amount to specific enforcement of the restructuring arrangement by compelling fresh funding and halting statutory recovery action. The Court held that such relief could not be granted because the borrower's liability to repay remained unconditional, the lenders were entitled to invoke their statutory remedies, and the insolvency regime operates as a comprehensive code with overriding effect. The petitioner's remedy, if any, for alleged non-disbursement of funds would lie elsewhere and not by blocking recovery proceedings.

Conclusion: The Court declined to restrain the lenders from pursuing recovery remedies or insolvency proceedings.

Final Conclusion: The petition failed in substance because the restructuring documents did not impose a binding duty to extend further funding, and the petitioner could not use the writ jurisdiction to compel specific performance of the financing arrangement or to interdict the lenders' statutory remedies.

Ratio Decidendi: Where a restructuring agreement expressly makes additional funding discretionary and not obligatory, a borrower cannot seek writ-based specific performance to compel further disbursement or restrain statutory recovery action; contractual repayment obligations and lenders' statutory remedies remain enforceable.

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