Agricultural land excluded from SARFAESI enforcement; possession order under the statute could not be sustained.

Security interest created in agricultural land is statutorily excluded from SARFAESI enforcement under Section 31(i), so the Act's possession and recovery machinery cannot be invoked against such land. Because the secured asset was undisputedly agricultural land, the District Magistrate's order passed within the SARFAESI framework was unsustainable and had to be set aside. The availability of other remedies to the secured creditor did not alter the statutory exclusion or validate action under the Act against agricultural land.

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Issues: Whether the SARFAESI Act, 2002 could be invoked in respect of security interest created in agricultural land, and whether the District Magistrate's order passed for taking possession was liable to be quashed.

Analysis: Section 31(i) excludes any security interest created in agricultural land from the operation of the SARFAESI Act, 2002. The land in question was undisputedly agricultural land, and therefore the statutory machinery for enforcement of security interest under the Act was not available. Once the Act was inapplicable to the secured asset, the order of the District Magistrate passed under the SARFAESI framework could not be sustained. The fact that the secured creditor may pursue other remedies in accordance with law does not alter the statutory exclusion.

Conclusion: The impugned order was liable to be set aside and the writ petition succeeded in favour of the petitioner.

Final Conclusion: The Court held that agricultural land is outside the reach of SARFAESI enforcement under Section 31(i), and the possession order based on that statute could not stand.

Ratio Decidendi: Security interest created in agricultural land is statutorily excluded from SARFAESI enforcement, and any recovery action taken under that Act against such land is unsustainable.

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