Prayer to the Honorable Debt Recovery Tribunal (DRT) in the Interest of MSME Economy and Public Money Safety

Subject: Prayer for Setting Aside the Order Against the Innocent MSME Borrower and Direction to ICICI Bank to Adhere to RBI’s MSME Policies for Loan Restructuring and Fund Release in the Larger National Interest

Honorable Presiding Officer,

The Applicant, an MSME Borrower, humbly submits this prayer for the following reliefs in light of the Nation’s MSME Economy and Public Money Safety:

1. Setting Aside the Order Against the MSME Borrower

1. The order against the Borrower must be set aside, as the actions of ICICI Bank have been proven malicious, pre-planned, and against the national economic interest.
2. ICICI Bank misrepresented and manipulated facts to misclassify the MSME loan, derail the fundamental objective of restructuring, and divert the DRT case towards wrongful possession.
3. The Bank’s actions were not in good faith but a conspiracy to seize valuable real estate, rather than ensuring proper loan recovery.

2. Adherence to RBI’s MSME Loan Restructuring Policies

4. ICICI Bank must be strictly ordered to follow RBI’s MSME policies, which are designed to protect the sector, especially during financial distress.
5. As per RBI Circulars on MSME restructuring, eligible borrowers must be granted relief and restructuring rather than being pushed into default.
6. The ICICI Bank’s intentional financial sabotage violated these policies, and they must be compelled to immediately restructure the loan in a fair and just manner.

3. Immediate Release of Unauthorized Withheld Funds (₹1.25 Crores)

7. The Bank’s unauthorized withholding of ₹1.25 Crores has crippled the MSME borrower’s financial stability, violating banking ethics and RBI guidelines.
8. These funds must be immediately released to restore MSME operations, ensuring business continuity and repayment capability.
9. Without these funds, ICICI Bank itself blocked the repayment process, proving its bad faith actions.

4. Upholding National Interest and Economic Stability

10. The DRT must prioritize national interest over the Bank’s conspiracy, ensuring MSMEs are not victims of corporate greed.
11. MSMEs are the backbone of India’s economy, and RBI policies exist to support their growth, not to facilitate unjust foreclosures.
12. A judicial intervention is essential to restore MSME financial health, safeguard public money, and prevent systemic financial abuse by banks.

5. Larger Interest for Everyone’s Benefit

13. A restructured MSME loan ensures full loan recovery with interest, benefiting both the banking sector and public money security.
14. Restoring the MSME will generate employment, sustain economic activity, and ensure fair financial practices.
15. Allowing ICICI Bank to misuse legal provisions for wrongful asset seizure will set a dangerous precedent, harming not only the Borrower but also countless MSMEs nationwide.

Final Prayer

In light of the above facts, the Applicant prays that the Honorable DRT:

• Set aside any adverse order against the Borrower, recognizing ICICI Bank’s fraudulent actions.
• Direct ICICI Bank to fully comply with RBI’s MSME restructuring policy and reinstate the Borrower’s loan under a fair repayment schedule.
• Order the immediate release of ₹1.25 Crores in withheld funds, which are essential for MSME restoration and national economic interest.
• Impose strict directions on ICICI Bank to prevent future financial sabotage against MSMEs.
• Recognize this case as a crucial precedent to protect MSMEs and uphold public financial safety.

This prayer is made in the larger interest of the nation’s MSME sector, public money security, and economic stability, ensuring justice prevails over corporate misconduct.

Respectfully Submitted,
SUNEIL CHAUDHARY
MSME Borrower & Applicant