Article 226 writ relief against private banks is limited where SARFAESI provides efficacious statutory remedies.

Writ jurisdiction under Article 226 is ordinarily not available against a private bank that is not shown to be discharging a public duty under Article 12. Where the dispute arises from measures taken under the SARFAESI framework, the Act's complete statutory mechanism, including remedies before the Tribunal and the Appellate Tribunal, must ordinarily be pursued first. The availability of an efficacious alternative remedy applies with greater force in such matters, and writ interference is generally declined. On the facts noted, the petition was found not maintainable and dismissed.

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Issues: Whether a writ petition under Article 226 was maintainable against a private bank and whether the availability of remedies under the SARFAESI Act barred interference.

Analysis: The dispute was directed against a private financial institution, which did not fall within the definition of State under Article 12 on the facts presented. The petition also concerned measures taken under the SARFAESI framework, which provides a complete statutory mechanism including remedies before the Tribunal and the Appellate Tribunal. In such matters, the rule of exhaustion of alternative remedy applies with greater force, and writ jurisdiction is ordinarily not invoked where an efficacious statutory remedy exists. A writ does not lie against a private person not shown to be discharging any public duty.

Conclusion: The writ petition was not maintainable and was dismissed.

Ratio Decidendi: Writ jurisdiction under Article 226 is not ordinarily available against a private bank not discharging public duty, particularly when the SARFAESI Act provides efficacious alternative statutory remedies.

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