Can I file a Section 17 SA at DRT Mumbai (Goa is under DRT Mumbai jurisdiction) without first replying to 13(2)?

Yes, but the absence of a 13(3A) reply weakens the SA. Best practice is to file a comprehensive 13(3A) reply within 15 days and then move the SA on receipt of the 13(4) possession notice.

Will the Bombay High Court at Goa stay a SARFAESI auction?

Only for narrow jurisdictional or procedural defects. Pricing or valuation disputes are routed to the DRT SA under Section 17. Satyawati Tondon is applied strictly.

What EMD/deposit is required to file a Section 17 SA?

Court fees under the DRT Regulations scale with claim value; there is no percentage deposit at SA stage (unlike DRAT). Ceiling on fees is ₹1.5 lakh.

Is a Section 14 SARFAESI CMM order appealable?

A CMM order under Section 14 is administrative and not directly appealable — it can be challenged in the Section 17 SA before the DRT.

Where do Goa borrowers file DRT SA?

At DRT Mumbai; camp sittings are held periodically at Panaji. Writs go to the Bombay High Court at Goa.

Are hospitality NPAs still elevated post-COVID?

Recovery has been strong but stressed units from FY21–22 remain in the OTS/restructuring pipeline.

Is communidade land auctionable under SARFAESI?

Communidade tenure creates significant title complexity — auction of such land requires deep diligence and often faces objections at registration.

Which bank has the largest Goa hospitality exposure?

SBI, Bank of Baroda and HDFC Bank collectively dominate the Goa hospitality lending book.

Goa • Legal defence

SARFAESI Defence & Consulting in Goa

We build the full SARFAESI defence stack for Goa borrowers — 13(3A) reply, Section 17 Securitisation Application at DRT Mumbai (Goa is under DRT Mumbai jurisdiction), and Article 226 writ before the Bombay High Court at Goa where jurisdictional/procedural defects justify it.

13(3A) reply to the 13(2) demand notice — statutory 15-day reply, drafted to preserve every objection.

Section 17 Securitisation Application at DRT Mumbai (Goa is under DRT Mumbai jurisdiction) against 13(4) possession / auction.

Interim application for stay of auction / possession under Rule 8/9 of the SARFAESI Rules.

Article 226 writ at the Bombay High Court at Goa for jurisdictional or Rule 8(6) notice defects.

Coordination with the borrower on Section 14 SARFAESI hearing before the CMM / CJM at Panaji.

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Written by

Sharad Wardhan

MD, NPA Experts

CA, ex-Deputy Vice President (Banking)

Legally reviewed by

NPA Experts Legal Review Panel

Empanelled counsel practising before DRT, DRAT and High Courts

Last updated

June 3, 2026

Editorial policy

This page is for general information. It is not legal, tax or investment advice. Every NPA / SARFAESI / DRT matter is fact-specific — speak to a qualified advisor before acting.

Goa

Everything a Goa borrower needs to know about SARFAESI Defence & Consulting

SARFAESI landscape in Goa

Goa's NPA base was materially reshaped by the 2018 mining lease expiry — mining-linked MSMEs remain a residual stress pool; hospitality NPAs spiked post-COVID. Goa's traditional communidade land holdings complicate auction diligence — buyer must verify tenure records at the Mamlatdar level. Bombay High Court at Goa applies the Satyawati Tondon threshold for writs — a writ is entertained only where the bank has breached statutory procedure, not on pricing or valuation disputes (those go to DRT).

The 15-day window after a 13(2) notice

Under Section 13(3A) SARFAESI, the borrower has 15 days to reply to a 13(2) notice and raise all objections. Silence or a weak reply materially prejudices the Section 17 SA later. We draft a reply that preserves every objection — non-service, wrong classification, misapplied appropriation, defective demand — and forces the bank to reply on record within 15 days of receipt.

Section 17 SA at DRT Mumbai (Goa is under DRT Mumbai jurisdiction)

Goa borrowers currently file at DRT Mumbai; camp sittings are periodically held at Panaji. A Section 17 SA is the primary defence to 13(4) possession or an auction notice. Interim stay is possible where the borrower can show a strong prima facie case of statutory breach or where Rule 8(6) 30-day sale notice was not properly served. Our advocates at DRT Mumbai (Goa is under DRT Mumbai jurisdiction) carry a full track record on SA filings against SBI and Bank of Baroda.

When to move the Bombay High Court at Goa

Writ is appropriate for: (a) jurisdictional defect — the account was wrongly classified NPA against the RBI IRAC Circular; (b) breach of natural justice — no 13(3A) reply was considered; (c) Rule 8(6) sale-notice defect not curable at DRT stage; (d) wilful-defaulter tag applied without a Show-Cause + Identification/Review Committee hearing under the July 2024 RBI Master Direction.

Local intelligence

Courts, lenders and hubs relevant to Goa

Court structure

Bombay High Court at Goa

Writ jurisdiction seat.

DRT Mumbai (Goa is under DRT Mumbai jurisdiction)

Goa borrowers currently file at DRT Mumbai; camp sittings are periodically held at Panaji.

Primary lenders

• SBI
• Bank of Baroda
• HDFC Bank
• ICICI Bank
• Axis Bank
• Goa State Co-operative Bank

Banking hubs

• Panaji
• Margao
• Vasco
• Mapusa

Stressed sectors

Hospitality & tourism; Mining ancillaries (post-2018 mining halt); Real estate; Fisheries

Auction / procedural note. Goa's traditional communidade land holdings complicate auction diligence — buyer must verify tenure records at the Mamlatdar level.

FAQ

SARFAESI Defence & Consulting — Goa FAQs

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