Authority: Court No. 12 GB

Order Date: 08 July 2026

Case Overview

  • Parties: Hemant Kanoria & Anr. (Applicants) vs. Punjab National Bank (Respondent).
  • Review application (RVW 172 of 2026 with CAN 1 of 2026) filed seeking review of the order dated 29 June 2026 passed in MAT 637 of 2026.
  • Applicants alleged that the earlier order failed to consider the complete record and the list of documents requested (see paragraph 115 of the impugned order).
  • Senior Advocate Jishnu Chowdhury highlighted an error in paragraph 9 of the appealed order, where it was incorrectly recorded that the applicants had submitted that PNB had monitored the loan accounts mentioned in the show‑cause notice.
  • The Court examined the show‑cause notice and the review applicant’s reply, noting that the applicant claimed PNB had monitored all loans and transactions listed in the notice and had prepared appraisal reports.

Corrected Paragraphs

  • Paragraph 9 (replaced):

> "It is submitted that the officials of PNB had monitored the loans and transactions mentioned in the show cause notice. Thus, we direct that the bank must supply the following documents, as they appear to be relevant, in the event PNB/bank had actually monitored the loans and transactions and had prepared appraisal reports on those transactions, namely,

> a. Copies of all appraisal reports prepared by the PNB officials in respect of the loan accounts and transactions mentioned in the show cause notice, in sections 6 and 7 of the KPMG's FAR.

> b. Copies of all the minutes of the meetings of the competent credit committee/special cell/relevant competent authority, in which the appraisal reports prepared by the PNB in respect of the loan accounts mentioned in the show cause notice and in the FAR of KPMG were considered and discussed.

> c. Copies of the minutes of all meetings held in PNB by the competent authorities in which all loan accounts and loan proposals of SREI Entities were placed and discussed for the purpose of sanctioning loans/enhancing limits to SREI Entities between 1 April 2015 and 4 October 2021."

  • Paragraph 10 (replaced):

> "With regard to the documents mentioned hereunder, PNB will endeavour to get hold of the documents either from KPMG or Saxena and Saxena or from any other bank(s) which are (is) member(s) of the consortium; and if received, shall supply the same to the applicant.

> a. Copies of the Detailed Appraisal Report (DAR) and Credit Assessment Memo (CAM) prepared by the relationship managers and regional heads of the SREI Entities of the transactions which were mentioned in the show cause notice and in sections 6 and 7 of the KPMG's FAR as also those mentioned in the FAR of Saxena and Saxena, under the same category of documents.

> b. Copies of the minutes of the meeting of the credit committee dealing with the approval/modification/appraisal of the loans which were disbursed and detailed in the show cause notice of the SCNs and in sections 6 and 7 of the KPMG's FAR and the FAR of Saxena and Saxena."

  • The original paragraphs 9 and 10 of the June 29, 2026 order are deleted and the above replacements are inserted.

Procedural Points

  • An affidavit of service was filed and taken on record.
  • The Court granted liberty to cure the defect.
  • The memorandum of review was filed, asserting that the earlier order omitted consideration of the full record and the document list.

Final Outcome

  • The review application is disposed of.
  • Parties are directed to act on the basis of the server copy of this amended order.

Topics: Court Order, Banking Document Disclosure