$~69 * IN THE HIGH COURT OF DELHI AT NEW DELHI Date of decision: 25^th March, 2026 Uploaded on: 30^th March, 2026 + W.P.(C) 3590/2026 & CM APPL. 17438/2026 DEVANG PRAVIN MODY .....Petitioner Through: Mr. Pranjit Bhattacharya, Ms. Salonee Shukla, Ms. Shalini Singh & Ms.

Souravi Das, Advs.

versus RESERVE BANK OF INDIA & ANR. .....Respondents Through: Mr. Ramesh Babu MR and Ms. Nisha Sharma, Ms. Manisha Singh and Ms.

Tanya Chowdhary, Advs. for R-1.

Ms. Seema Gupta, Adv. for Respondent No 2 CORAM:

JUSTICE PRATHIBA M. SINGH JUSTICE MADHU JAIN Prathiba M. Singh, J. (Oral)

1. This hearing has been done through hybrid mode.

2. The present petition has been filed under Article 226 of the Constitution of India challenging the Master Directions on Fraud Risk Management in Commercial Banks (including Regional Rural Banks) and All India Financial Institutions bearing No. RBI/DOS/2024-25/118 DOS.CO.FMG.SEC.No.5/23.04.001/2024-25 dated 15th July, 2024 (hereinafter, ‘the impugned Directions’), issued by the Reserve Bank of India (hereinafter, ‘RBI’).

3. The Petitioner also challenges the Show Cause Notice dated 29^th October, 2025 (hereinafter, ‘SCN’) and the consequent impugned order dated

18^th February, 2026 (hereinafter, ‘the impugned order’), classifying the Petitioner’s accounts as ‘Fraud’.

4. The brief background of this petition is that a substantial amount of wholesale loans were disbursed to M/s Reliance Commercial Finance Limited (hereinafter ‘RCFL’) by a consortium of banks. According to the impugned order, the total amount disbursed was a sum of Rs.16,455.62 crores and the loans which were disbursed to the linked entities amounted to Rs.11,218.58 crores.

5. The Petitioner was one of the key managerial personnel of the said company- RCFL and had held various positions therein, such as Additional Director, Executive Director, CEO, Whole Time Director, etc.

6. The last tranche of loan facilities was extended in December, 2016. In April, 2017, the Petitioner was appointed as the CEO of RCFL and it is his case that he ceased to be the CEO and Whole Time Director from 31^st December, 2018 and also resigned from the employment of RCFL.

7. The further case of the Petitioner is that from 5^th July, 2019 onwards, he is serving as Managing Director of Bajaj Finserv Health Limited.

8. From 2020-2021, several banks classified the loan account of RCFL as Fraud under the Master Directions on Frauds– Classification and Reporting issued in 2016 by RBI. This was challenged by RCFL in various petitions before this Court.

9. In addition, the Supreme Court also decided the questions relating to the said Master Directions on Frauds– Classification and Reporting issued in 2016 by RBI in a batch of matters, titled State Bank of India v. Rajesh Agarwal, (2023) 6 SCC 1. Various directions were issued to the RBI, by the Supreme Court, in the said judgment.

10. As per the RBI, it was pursuant to the said decision in SBI Vs. Rajesh Agarwal (supra) a fresh Master Direction document was issued by the RBI dated 15^th July, 2024 which are the impugned directions in the present petition.

11. Parallelly, some of the banks which are part of the consortium had declared the Petitioner as “fraud” and writ petitions were filed by the Petitioner before this Court being W.P.(C) 7034/2025 titled Devang Pravin Mody v. Bank of India and W.P.(C) 7696/2025 titled Devang Pravin Mody v. Punjab National Bank & Ors. These petitions were filed in respect of loans / credit facilities extended by Bank of India and Punjab National Bank.

12. In the present case, the Respondent No.2 is Punjab and Sind Bank. The said bank had issued a SCN to several individuals, including Mr. Dhananjay Tiwari Bhagwanprasad and the Petitioner - Mr. Devang Pravin Mody.

13. It is the case of the Petitioner that the SCN dated 29th October, 2025 which was issued to him, was not delivered to the Petitioner and hence, no reply could be filed. The SCN led to the passing of the impugned order dated

18^th February, 2026 by which it has bee