regarding disclosure of division of share of the project through an Affidavit.<\/strong><\/span><\/p>\nAs per Notice issued by the Bihar RERA on 01.08.2023, in order to avoid litigation regarding share of promoter and landowner in the project available for selling and marketing, a notice was earlier issued by Bihar RERA on 01.07.2022 vide No. 60 for disclosure of share of promoter in the project through an affidavit. However, it was noticed that in some cases promoters submit the memorandum of division of share signed between promoter and landowners on stamp paper in compliance of one of the conditions of development agreement.<\/p>\n
As per this Notice dated 01.08.2023, promoter would henceforth, submit the details of division of share of the project available for marketing and selling on Affidavit duly executed between promoter and landowner\/s in a particular format with the application to be submitted for the registration of project. The said direction has come into force with immediate effect for all the applications to be submitted henceforth for registration. The format for such declaration is also attached with the said notice.<\/p>\n
Press Release dated 03.08.2023 issued UP RERA regarding suo moto action against non-compliance of UP RERA order by promoter.<\/strong><\/span>\u00a0<\/strong><\/p>\nAs per the press release dated 03.08.2023, the ADJ Bench of the UP RERA, in the interest of homebuyers, exercised its statutory rights and itself got the sale deed executed and registered in favour of the complainant homebuyer where after constant persistence, the promoter was not registering the sale deed in favour of the aggrieved homebuyer.<\/p>\n
This step would send a message to the promoters that UP RERA will continue to fulfil the responsibility of safeguarding the interest of the homebuyers by taking actions as per the rules formulated.<\/p>\n
As per the UP RERA, it is the responsibility of UP RERA to protect the transparency between the promoter and the homebuyer and it shall continue to enforce the provisions of the Real Estate (Regulation and Development) Act, 2016 (\u201cRERA Act<\/strong>\u201d) in the state.\u00a0<\/strong><\/p>\nOffice Order: dated 08.08.2023, issued by <\/strong>Bihar RERA regarding SOP for dealing with the Projects where the date of completion, as mentioned in the application for registration, has been exceeded, Project has come under lapsed category and application for extension is not submitted within time.<\/strong><\/span><\/p>\nAs per Office Order dated 08.08.2023 of Bihar RERA, it was acknowledged that there have been various instances where the promoter of a real estate project failed to renew the validity of a project registered with RERA within the stipulated time. To safeguard the interest of the allottees in such an instance, the Authority had earlier offered a General Amnesty Scheme and allowed the promoters to apply for extension with additional amount of fees up to a maximum period of delay of 2 (two) years.<\/p>\n
The validity of the Amnesty Scheme was over and therefore, Bihar RERA had to streamline a procedure to be adopted by the office for dealing with such applications that are received for extension.<\/p>\n
As per the SOP issued by the Authority, which comes into force with immediate effect, if the promoter submits an application, in prescribed format, for extension stating the compelling reasons \/ circumstances for failure to complete the project on time and satisfy the Authority in believing that the project is near completion, then such case would be referred firstly to the Legal Section.<\/p>\n
All applications received from promoters:<\/p>\n
\n- would contain the consent of 2\/3rd<\/sup> (two-third) of allottees of the project that they want to get the remaining development work to be carried out by the same promoter and they have no objection if the period of completion is extended.<\/li>\n
- be examined for any pending complaint against the project. If any complaint case is pending, then the decision of the Presiding Officer will be given deciding whether such project needs to be extended or not.<\/li>\n<\/ul>\n
However, if no complaint case is pending:<\/p>\n
\n- The said matter would be referred to compliance wing to check whether the obligations are being met by the promoter and the requisite reports are being reported regularly. The department ensures the compliance and the deposition of the requisite penalty amount.<\/li>\n
- The compliance of the conditions shall be examined by the Bihar RERA along with the examination of the application documents as prescribed under the relevant provisions of the RERA Act along with the Rules made thereunder being duly submitted.<\/li>\n
- The department will then examine the exceptional circumstances as pleaded by the promoter in the application along with other compliances required.<\/li>\n
- The map of the project will also be an essential parameter to be considered by the department.<\/li>\n
- After being satisfied of the above conditions, the period of delay (which was limited to 2 years under the General Amnesty Scheme may then be extended.<\/li>\n
- For delay of every quarter, promoter needs to submit additional fees for delay at the rate of 50% (fifty per cent) of the registration fees.<\/li>\n<\/ul>\n
The final extension will be provided by the Authority only after being satisfied of whether the time proposed by the promoter to complete the project is reasonable or not. It has been clarified in the said Office Order dated 08.08.2023 that it shall not be interpreted to mean that in every case a promoter who fails to complete the project under the extended time under section6 would get further extension as of right to complete the remaining development work.<\/p>\n
Circular No.<\/strong> No: 1\/RERA\/Circulars\/2019\/798 dated 11.08.2023 issued by Goa RERA regarding adherence to model format of Agreement for Sale (AFS). <\/strong><\/span><\/p>\nAs per Circular dated 11.08.2023, it has been mentioned that Goa RERA has come across several complaints that some builders are incorporating restrictive clauses in the AFS and are deviating from Model AFS Rules notified by the Ministry of Housing and Urban Affairs, New Delhi.<\/p>\n
It was further mentioned in the said circular that despite some leeway provided, depending upon circumstances of each case, by the Rule 10(1) and 10(2) under Agreement for Sale along with explanatory note to the Model Form of Agreement notified by Goa RERA, there are certain mandatory clauses which need to be strictly retained by the promoters in the AFS executed between the promoter and the Allottee. Also, any change in the agreement found contrary to or inconsistent with any provisions of the Act, Rules and Regulations would be void-ab-initio.<\/p>\n
In view of the same, Goa RERA, vide its circular dated 11.08.2023 has directed that all existing as well as prospective promoters under the Goa RERA to adhere to the Model format of AFS.<\/p>\n
Order No. K-RERA\/T3\/2127\/2023 dated 19.08.2023 issued by Kerala RERA regarding display of QR code in every project promotion advertisement. <\/strong><\/span><\/p>\nAs per Order of Kerala RERA dated 19.08.2023, in exercise of the powers conferred on the Authority under Section 37 of the RERA Act, i.e., to issue directions to promoter, real estate agents and allottees from time to time, the Kerala RERA has issued the following direction:<\/p>\n
\n- The promoter shall prominently display QR code on each and every project advertisement, 01.09.2023 onwards.<\/li>\n
- Such QR Code must be legible, readable and detectable with software application.<\/li>\n
- The QR Code of each registered project is made available for download in the promoters dashboard located close to the certificate download section.<\/li>\n
- Such QR Code must be published besides the Kerala RERA Registration Number and the website address.<\/li>\n
- Mediums of advertisements on which it applies include newspaper, magazines, journals, printed flyers, brochures, catalogues, leaflets, prospectus, standees on project sites, sales office, websites, webpages, social media platforms or any other medium where QR Code can be published.<\/li>\n<\/ul>\n
NCLT Brief<\/em><\/strong><\/span><\/h3>\nCase Referred- M\/s IFCI Ltd. Vs. Sutanu Sinha (Comp App (AT) (CH) (Ins) No. 108\/2023)<\/strong><\/span><\/p>\nIssue<\/strong>: Whether the Compulsorily Convertible Debentures (\u201cCCD<\/strong>\u201d) would be treated as equity or as a debt instrument for the purpose of the Insolvency and Bankruptcy Code (\u201cCode<\/strong>\u201d) and whether the amount due and payable from the CCD would fall within the definition of \u2018Financial Debt\u2019 as defined under the Code?<\/p>\nBrief Facts of the Case<\/u><\/strong><\/p>\nIVRCL Limited (\u201cIVRCL\u201d<\/strong>) won a bid in April 2009 for undertaking construction, operation, and maintenance of a project under \u2018National Highway Authority of India\u2019 (\u201cNHAI<\/strong>\u201d). Pursuant thereto, a concession agreement was entered into between the subsidiary of IVRCL, i.e., IVRCL Chengapalli Tollways Limited (\u201cCorporate Debtor<\/strong>\u201d) and NHAI for the execution of the said project. Furthermore, IFCI Bank (\u201cAppellant<\/strong>\u201d) agreed to provide financial assistance to the Corporate Debtor for execution of the project through CCDs issued by the Corporate Debtor.<\/p>\nThe Appellant had agreed to subscribe to CCDs amounting to Rs. 12.5 crores vide a \u2018Debenture Subscription Agreement\u2019 (\u201cDSA\u201d<\/strong>). The Corporate Debtor, IVRCL and the Appellant entered into a share buy-back agreement dated 14.10.2011, wherein the terms and conditions of the buy-back of aforementioned CCDs subscribed by the Appellant were mentioned. Furthermore, DSA empowered Appellant to sell the CCDs to a third party. \u00a0<\/p>\nVide order dated 20.04.2020, the National Company Law Tribunal, Hyderabad Branch (\u201cNCLT<\/strong>\u201d) initiated the Corporate Insolvency Resolution Process (\u201cCIRP\u201d<\/strong>) of IVRCL. Pursuant thereto, the Appellant filed a claim with the Resolution Professional of the Corporate Debtor; however, the same was rejected. Subsequently, the Appellant filed an application challenging the rejection of claim before the NCLT and the NCLT upheld the decision of the resolution professional rejecting the claim of the Appellant.<\/p>\nThe NCLT held that the CCDs subscribed by the appellant was to be treated as equity and not as debt. The NCLT also held that the CCDs cannot acquire the status of debt on default because interest on CCDs is to be paid by the sponsor, i.e., IVRCL, the holding company of Corporate Debtor and the Corporate Debtor was not under any obligation to pay interest on the borrowing.<\/p>\n
Aggrieved by the aforesaid order, the Appellant preferred an appeal before the National Company Law Appellate Tribunal, Chennai (\u201cNCLAT<\/strong>\u201d).\u00a0<\/p>\nObservation and Decision of NCLAT<\/u><\/strong><\/p>\nThe NCLAT held that in the present case, the CCDs had matured before the initiation of CIRP proceedings of the Corporate Debtor. The NCLAT observed that it is evident from the record that the investment was in the form of debentures which would be converted into equity. Furthermore, the terms and conditions of the DSA and the parties intent did not specify anywhere that the instrument would acquire the nature of a financial debt in the occurrence of any event which was evident from the provisions of the Loan Agreement and the Concession Agreement executed between NHAI and the Corporate Debtor, which define equity to include CCDs as part of the Project’s equity component.<\/p>\n
Thus, the NCLAT held that the CCDs are equity instruments and do not fall within the definition of Financial Debt as defined under Section 5(8) of the Code. Hence, the NCLAT dismissed the appeal.<\/p>\n
Litigation Brief<\/em><\/strong><\/span><\/h3>\nHigh Courts should not entertain Writ Petitions in Commercial matters in case of existence of an alternative remedy<\/strong><\/span><\/p>\nCase referred: M\/S. South Indian Bank Ltd. & Ors. vs. Naveen Mathew Philip & Anr. etc. Civil Appeal No. 002861 \u2013 002862 \/ 2023<\/strong><\/p>\nThe two-judge bench of Justice Sanjiv Khanna and Justice M.M. Sundresh held that in commercial matters, litigants cannot be permitted to bypass the route of approaching tribunals.<\/p>\n
The Supreme Court had taken note of the issue of non-functional Debt Recovery Tribunals (DRTs) and Debt Recovery Appellate Tribunals (DRATs) and requested the relevant High Courts to handle cases falling under their jurisdiction through Article 226 of the Indian Constitution. In the present case, the Borrowers challenged a Notice issued by the Bank under Section 13(2) of the SARFAESI Act by filing a writ petition before the Kerala High Court. The High Court instructed the Bank to consider the Borrowers’ repayment proposal and allowed them to repay the dues in installments. However, the Borrowers failed to comply with the arrangement. Consequently, the Bank issued notices under Section 13(4) of the SARFAESI Act to the Borrowers in December 2021.<\/p>\n
Due to the non-functioning of the DRT, the Borrowers filed another writ petition before the Kerala High Court, challenging the Notice under Section 13(4) of the SARFAESI Act and requesting the Bank to accept deferred payments. The High Court granted the Borrowers the opportunity to make deferred payments to the Bank within a period of 12 months. Subsequently, the Bank appealed to the Supreme Court, arguing that since an equally effective remedy was available, the extraordinary jurisdiction of the High Court under Article 226 of the Indian Constitution should not have been invoked.<\/p>\n
The present appeal was filed before the Apex court by the Bank against the order of the High Court arguing that since an equally effective remedy was available, the extraordinary jurisdiction of the High Court under Article 226 of the Constitution of India could not have been invoked.<\/p>\n
The Hon\u2019ble Supreme Court in consideration of the aforesaid facts, observed that:<\/p>\n
Although DRT was not functional at the time of filing the writ petitions by the Borrowers, it became functional from March 2022 and matters should have been relegated to the Tribunal by the High Court. When a right is created by a statute, which itself prescribes the remedy or procedure for enforcing the right or liability, resort must be had to that particular statutory remedy before invoking the discretionary remedy under Article 226 of the Constitution. More circumspection is required in a financial transaction, particularly when one of the parties would not come within the purview of Article 12 of the Constitution. This rule of exhaustion of statutory remedies is a rule of policy, convenience, and discretion.<\/p>\n
The Hon\u2019ble Supreme Court observed that the High Court has erred in ignoring the existence of alternate remedies under the Securitization and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 (SARFAESI Act) and wrongly exercised its discretionary power under Article 226 of the Constitution of India to resolve commercial disputes between a lender and a borrower.<\/p>\n
Stamping out Uncertainty: Delhi High Court’s Ruling on Appointment of Arbitrators Vis-\u00c0-Vis Unstamped Arbitration Agreements <\/strong><\/span><\/p>\nIN THE MATTER OF:<\/strong> Splendor Landbase Ltd. Vs. Aparna Ashram Society & Anr.<\/p>\n(Pronounced by the Hon\u2019ble High Court of Delhi on 22.08.2023 in the ARB. P. 366 of 2021) <\/em><\/p>\nFacts: <\/strong><\/p>\n\n- The Judgement has been passed in a batch of Petitions filed under Section 11 of the Arbitration & Conciliation Act, 1996 [\u2018A&C Act<\/strong>\u2019] seeking appointment of an Arbitrator admittedly under unstamped \/ deficiently stamped arbitration agreements. The Delhi High Court ruling lays out the interplay between the Indian Stamp Act, 1899 [\u2018Stamp Act<\/strong>\u2019] and the A&C Act in light of the judgment passed by the Hon\u2019ble Supreme Court in the case of N.N. Global Mercantile (P) Ltd. Vs. Indo Unique Flame Ltd. (2023) 7 SCC 1<\/em><\/strong>.<\/li>\n
- A major impediment dealt by the present case revolves around the issue as to whether an unstamped or insufficiently stamped contract \/ arbitration agreement, that ought to be mandatorily stamped under the Stamp Act, be impounded by the court if such a document is produced in evidence and the procedure thereof.<\/li>\n
- The judgement also elucidates upon practical impediments faced by practitioners and parties alike, i.e., in a situation where an instrument is executed in one state and the document is presented in a proceeding under Section 11 of the A&C Act in another state, the local stamp laws of which state would be applicable on the instrument.<\/li>\n<\/ol>\n
Issues before the Court: <\/strong><\/p>\n\n- Whether it is incumbent on the petitioner to file the original of the duly stamped arbitration agreement\/contract or a ‘true copy’ filed thereof would suffice?<\/li>\n
- Whether it is permissible for the petitioner to pay the deficient stamp duty with penalty or whether it is mandatory for the court to send the concerned agreement\/contract to the Collector for adjudication of proper stamp and penalty payable thereon?<\/li>\n
- Whether the adjudication by the Collector under Section 40 of the Stamp Act can be made time bound?<\/li>\n
- Whether the stamping of arbitration agreement\/contract must conform to the local laws\/stamping rate(s) prescribed at the place where the arbitration agreement\/contract was executed and\/or whether the same are required to conform to the relevant prescription at the place where the petition under Section 11 of the Arbitration and Conciliation Act, 1996 has been filed?<\/li>\n<\/ul>\n
Court Observation and Findings: <\/strong><\/p>\n\n- If the agreement is not properly \/ deficiently stamped, the court is mandated to impound the instrument in terms of the judgment passed by the Hon\u2019ble Supreme Court in N.N. Global (supra).<\/li>\n<\/ol>\n
\n- The Petitioner has to file the original instrument if the petition under Section 11 of the A&C Act is filed on the basis of unstamped\/insufficiently stamped agreement. This is not a requirement when the agreement is duly stamped.<\/li>\n<\/ol>\n
\n- The court, while considering a petition seeking appointment of an arbitrator, basis an unstamped\/deficiently stamped arbitration agreement has the following two options:<\/li>\n<\/ol>\n
(i) To send the impounded agreement to the Collector of Stamps for ensuring payment of deficit stamp duty with penalty. Thereafter, the instrument shall be admissible in evidence and it would be open for the court to act on that basis in the proceeding under Section 11 of the A&C Act. The court can also direct the Collector to complete the process in a time- bound manner.<\/p>\n
(ii) Where the stamp duty payable is not in dispute, the court can direct the parties to deposit the requisite stamp duty along with penalty in the court itself. Thereafter, an authenticated copy of such instrument be sent to the Collector along with the amount so collected. If the Collector is aggrieved by the decision of the court as regards the duty and\/or penalty payable, it would be open for the Collector to move the concerned Appellate Court under Section 61 of the Stamp Act.<\/p>\n
\n- Regarding an instrument executed in one state but sought to be relied \/ acted upon and received in another state, the legal precedent set by the Supreme Court in the case of New Central Jute Mills Co. Ltd. v. State of West Bengal [AIR 1963 SC 1307] <\/em>must be adhered to. According to the principles established in the aforementioned case, such an instrument should be stamped in accordance with the laws of the first state, and there is no need for further stamping in accordance with the laws of the second state if the stamp duty rates in the second state are same or lower than those in the first state. However, if the stamp duty rates in the second state are higher, the instrument will only require additional stamping for the excess amount based on the rates applicable in the second state.<\/li>\n<\/ol>\n
CONCLUSION <\/strong><\/p>\nThe captioned judgment passed by the Hon\u2019ble Delhi High Court answers a lot of questions which arose in the aftermath of the N.N. Global (supra) and proves to be a guiding beacon going forward in cases of appointment of an arbitrator under an unstamped \/ deficiently stamped arbitration agreement.<\/p>\n
Decoding the meaning of \u201cCommercial purpose\u201d in Consumer Protection Act<\/strong><\/span><\/p>\nCASE ANALYSIS: Rohit Chaudhary & Another vs. M\/S Vipul Limited, (2023 SCC Online SC 1131)<\/strong><\/p>\nDecided by Hon\u2019ble Supreme Court on 06.09.2023<\/strong><\/p>\nFactual Matrix: <\/strong><\/p>\n\n- The Appellants planned to buy commercial space in the ‘Vipul World Commercial’ project in Gurugram, Haryana. They agreed to purchase shares from two sellers, paid the agreed amount, and had their names recorded as owners. The Respondents later demanded outstanding payments, which the Appellants paid promptly. The Appellants received a receipt and an allotment letter for ‘Vipul Business Park’ but were then reassigned a different plot without their consent.<\/li>\n
- When the Appellants objected to this unilateral change, the Respondents threatened to forfeit their payments and cancel the allotment. The Respondents sent a buyer’s agreement to the Appellants, which they signed and returned. However, the Respondents failed to deliver possession of the premises within the agreed period of 24 months.<\/li>\n
- Aggrieved by the lack of communication and action, the Appellants filed a complaint with the National Consumer Dispute Redressal Commission in New Delhi. However, the Commission dismissed the complaint applying the commercial purpose test, stating that the Appellants didn’t qualify as ‘consumers’ under Section 2(1)(d) of the Act because they were already engaged in business for their livelihood, and the property in question was not solely for self-employment purposes.<\/li>\n<\/ol>\n
Issue in question:<\/strong><\/p>\nWhether the Appellants in such case are the \u2018Consumers\u2019 and what is the meaning of \u201cCommercial purpose\u201d under the Consumer Protection Act, 1986?<\/p>\n
\u00a0Court\u2019s Observations and Findings:<\/strong><\/p>\n\n- In the present appeal, Hon\u2019ble Supreme Court clarified that the definition of ‘Consumer’ under Section 2(1)(d) of the Act excludes individuals who purchase goods or services for resale or for large-scale profit-making activities. However, if a consumer complaint asserts that goods were bought for earning a livelihood, it should not be dismissed outright.<\/li>\n
- The court emphasized that the decision to proceed with such a complaint should be based on the specific facts and circumstances of each case, and there is no fixed formula for determining whether a complainant falls within the definition of a ‘consumer’ under the Act.<\/li>\n
- In this case, the Appellants had clearly stated in their complaint that they sought office space for self-employment and to run their business for their livelihood, not for resale or investment. The Court found the National Commission’s decision to be erroneous and not in line with the Act’s definition of a ‘consumer.’<\/li>\n
- Considering that the dispute dated back to 2006 and that the Appellants had paid over Rs. 51 lakhs to the developer after which also the allotted office space was not delivered as per the agreed timeframe, the Apex Court directed the Respondent developer to refund the amount received from the Appellants with interest calculated at 12% per annum.<\/li>\n
- This decision aimed to balance the equities and provide justice to the Appellants while considering the appreciated value of the asset, i.e., the office premises intended for sale to the Appellants.<\/li>\n
- In conclusion, the Hon\u2019ble Supreme Court allowed the appeal, overturned the NCDRC’s order, and instructed the Respondent developer to refund the amount along with interest to the Appellants who filed the complaint.<\/li>\n<\/ol>\n
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