The relation between strict procedural compliance and substantive justice under the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 (SARFAESI Act) continues to generate significant judicial discourse. In a recent pronouncement, the High Court of Chhattisgarh, speaking through Hon’ble Justice Amitendra Kishore Prasad in Central Bank of India v. State of Chhattisgarh and Ors., WPC No. 2314 of 2026, decided on 11 May 2026, addressed the critical question of whether the non-production of an authorization letter by an Authorized Officer under Section 14 of the SARFAESI Act constitutes a fatal defect warranting outright dismissal, or merely a curable procedural irregularity amenable to rectification. The judgment assumes particular significance for secured creditors navigating the enforcement mechanism under the SARFAESI Act, while simultaneously reaffirming the sanctity of principles of natural justice even in summary recovery
