Case Commentary: Impact of Bank of India v. M/s Sri Nangli Rice Mills Pvt. Ltd

This commentary analyses the Supreme Court's judgment of 23 May 2025 in Bank of India v. M/s Sri Nangli Rice Mills Pvt. Ltd., a dispute between two banks over the same collateral. The Court held that Section 11 of the SARFAESI Act makes arbitration mandatory for specified disputes between banks, financial institutions, asset reconstruction companies and qualified buyers, with or without a written agreement, and that the DRT has no jurisdiction. The commentary also notes the rejection of the AMRCD Memorandum argument, points for lenders, and open questions on lender-borrower disputes and pending DRT proceedings.