In this case, Manoj Lalwani, Director of Ritu Automobiles Pvt. Ltd., filed a writ petition challenging HDFC Bank’s recovery proceedings after the company’s loan account was classified as an NPA on October 21, 2019. A demand notice was issued under the SARFAESI Act, and an e-auction was scheduled for June 21, 2025. The Bombay High Court dismissed the petition, primarily on the ground of lack of locus standi, as the company had entered liquidation under IBC. Since October 10, 2024, the company’s management powers vested with the liquidator, making the director legally incapable of filing such a petition. The court further held that MSME restructuring benefits under the RBI’s 2016 circular were inapplicable, as the company’s outstanding dues exceeded ₹30 crores. No evidence was provided to show the borrower had approached the bank under the MSME framework. The court emphasized that once CIRP begins, directors cannot represent the company, and found the petition a misuse of process to delay recovery. It was dismissed without costs.