outstanding loan of Rs. 8,79,952/- disbursed under the agreement dated 31.10.2016 and would be deemed to be at it is with this understanding, an agreement dated 30.04.2018 was executed between the Applicants and Respondent No.1, thereby novating the terms of earlier agreement dated 31.10.2016; that out of the total financial assistance of Rs. 13,75,000/- disbursed under the agreement dated 30.04.2018, Rs. 8,79,952/- were adjusted against the dues pending against agreement dated 31.10.2016; that to put in perspective out of financial assistance granted under the agreement dated 30.04.2018, all the dues under the previous agreement stood paid and accounts were finally settled, with nothing remained due; that no security in any form whatsoever, much less in the form of mortgage by deposit of title deeds was sought from the Applicants by the Respondent No.1, nor was deposited with the Respondent No.1 to secure the financial assistance granted under the agreement dated 30.04.2018; that no security interest whatsoever stood created under agreement dated 30.04.2018 upon any of the immovable property of the Applicants, much less in residential unit measuring 8 Marlas, situated at `Khasra No.1455 (5-7), Khewat No.638, Khatauni No.821, Moga Jit Singh-2, Moga; that due to COVID-19 pandemic and due to lock-down, the Applicants, who are rendering the wood and steel works, suffered immense losses after paying about Rs. 9,25,000/- till December of 2020 and further failed to re-pay the financial assistance disbursed under the agreement dated 30.04.2018 and as a consequence of such default thereof, their account was classified as Non-Performing Asset (NPA) w.e.f. 05.07.2020; that on a completely misplaced and misconceived reliance on the terms of agreement dated 30.04.2018, rather in a manner which smacks of malice and fraud, Respondent No.1 appointed Respondent No.2 an Asset Reconstruction Company, to be its assignee to recover such loan; that it is in furtherance of assignments of rights, Respondent No.2 assuming itself to be a secured creditor, issued a notice under Section-13(2) of the Act, calling upon the Applicants to pay a sum of 22,33,067.50p within 60 days; that pursuant to the issuance of notice under Section 13(2)
