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    <title>2021 (8) TMI 699 - NATIONAL COMPANY LAW APPELLATE TRIBUNAL, PRINCIPAL BENCH , NEW DELHI</title>
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    <description>In a statutory public auction under the SARFAESI framework, title passes when the bid is accepted and the sale is confirmed; the sale certificate is only evidence of that title and no separate conveyance deed is required. On the facts, the secured asset had progressed through possession, sale notice, e-auction, confirmation of sale, payment of the balance consideration, and issuance of the sale certificate before commencement of CIRP. Registration of the sale certificate did not alter the completed transfer, and the later insolvency moratorium could not unsettle a transaction already concluded. The challenge to cancellation of the sale therefore failed, and the sale in favour of the auction purchaser was upheld.</description>
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      <description>In a statutory public auction under the SARFAESI framework, title passes when the bid is accepted and the sale is confirmed; the sale certificate is only evidence of that title and no separate conveyance deed is required. On the facts, the secured asset had progressed through possession, sale notice, e-auction, confirmation of sale, payment of the balance consideration, and issuance of the sale certificate before commencement of CIRP. Registration of the sale certificate did not alter the completed transfer, and the later insolvency moratorium could not unsettle a transaction already concluded. The challenge to cancellation of the sale therefore failed, and the sale in favour of the auction purchaser was upheld.</description>
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