Allowed

Canara Bank v. M/s Shyam Trading

DRT3 Sept 2025OA/277/2024

Case brief

AI extract

What is this about?

The Debts Recovery Tribunal determined the debt of Rs.67,90,922 owed by a proprietorship firm and its guarantor to Canara Bank. After finding the evidence unchallenged by defendants who failed to appear, the Tribunal allowed the recovery application and issued a recovery certificate. The order includes future interest at 10% p.a. and an injunction against asset transfer. This case deals with banki

What did the court decide?

The bank was granted a recovery certificate for Rs.67,90,922 with interest @10% p.a. from the filing date. The mortgaged assets were attached, and a bar was placed on transferring them until dues were

Canara Bank versus M/s Shyam Trading — Banking and Recovery | DRT (2025)

OA 277 of 2024jJl

DRT, PATN A

Debts Recovery Tribunal, Patna

¶5

Karpuri Thakur Sadan, Aashiana Digha Road Patna-800025

¶6

Presiding Officer : Shri Kaushalendra Yadav

¶7

OA Case No. 277 of 2024

¶8

Canara Bank, Lakhisarai Branch, PO.- Lakhisarai, P.S.- Kawaiya, DistrictLakhisarai

¶9

. . . . . . .Applicant

¶10

¶11

M/s Shya rn Trading, at Pachna Road, Bypass Road, Lakhisarai, P.O.Lakhisarai, P.S.- Kawaiya, District- Lakhisarai- 841435, a proprietorship concern through its proprietor Arati Devi, W/o Shyam Kumar Verma

¶12

Arati Devi, W/o Shyam Kumar Verma, R/o Pachna Road, Sankar Pokhar, Lakhisarai, P.O.-Lakhisarai, P.S.-Kawaiya, District- Lakhisarai, PAN No.BLXPD1716K

¶13

Shyam Kumar Verma, S/o Sopendra Prasad Verma, R/o Pachna Road, Sankar Pokhar, Lakhisarai, P.O.- Lakhisarai, P.S.- Kawaiya, DistrictLakhisarai, PAN No.AFHPV5985R

¶14

. . . . . . . Defendants

¶15

Present:

¶16

For the Applicant For the Defendant no.2

¶17

Shri Onkar Kumar, Advocate Shri Bijay Kumar Pandey, Advocate Shri Mukesh Kumar, Advocate

¶18

Dated :03.09.2025

¶19

JUDGMENT

¶20

The Applicant bank has made this application u/s 19 of the Recovery of Debts and Bankruptcy Act, 1993 (here-in-after referred to as Act) on 15.05.2024 against the defendants to recover its debts from defendants of IB.67,90,922/- as on 04.04.2024 along with pendente-lite and future interest at the contractual rate from 05.04.2024 with costs till realization.

¶21

The application has been filed with the contention that the applicant bank, is a body corporate, carries on the business and is competent to file the suit through various branches including the applicant.

OA 277 of 20241JI

DRT+ PATNA

Defendant no.1 is a proprietorship firm of which defendant no.2 is the proprietor. Defendant no. 3 is the guarantor. Defendants approached the applicant bank for sanction of Cash Credit loan (OCC Facility) of Rs.4 Lakh vide loan application dated 11.09.2013, which was sanctioned by the applicant bank on 11.09.2013 on various terms and conditions, as stipulated in the sanction letter, which were duly accepted by the defendants. To secure the loan facilities defendants have executed various loan and security documents and also created mortgage in favour of the applicant bank, details of which are given in OA.

¶26

Pursuant to the request of the defendants for enhancement of the limit upto Rs.8 Lakh, the applicant bank extended the said credit facility to Rs.8 Lakh on 08.08.2014 on various terms and conditions, as stipulated in the sanction letter, which were duly accepted by the defendants. To secure the loan facilities defendants have executed various loan and security documents and also created/extended mortgage in favour of the applicant bank, details of which are given in OA.

¶27

Pursuant to the request of the defendants for enhancement of the limit upto Rs.20 Lakh, the applicant bank extended the said credit facility to Rs.20 Lakh on 19.05.2015 on various terms and conditions, as stipulated in the sanction letter, which were duly accepted by the defendants. To secure the loan facilities defendants have executed various loan and security documents and algo created/extended mortgage in favour of the applicant bank, details of which are given in OA.

¶28

Pursuant to the request of the defendants for enhancement of the limit upto Rs.30 Lakh, the applicant bank extended the said credit facility to Rs.30 Lakh on 16.06.2016 on various terms and conditions, as stipulated in the sanction letter, which were duly accepted by the defendants. To secure the loan facilities defendants have executed various loan and security documents and also created/extended mortgage in favour of the applicant bank, details of which are given in OA.

¶29

hAq D e b :r :: ::IT:f : : :: tIIEIII!iII

OA 277 of2024jJ1

DRT, PATNA

Pursuant to the request of the defendants for enhancement of the limit upto Rs.48 Lakh, the applicant bank extended the said credit facility to Rs.48 Lakh on 19.07.2017 on various terms and conditions, as stipulated in the sanction letter, which were duly accepted by the defendants. To secure the loan facilities defendants have executed various loan and security documents and also created/extended mortgage in favour of the applicant bank, details of which are given in OA. The said facility was renewed on 28.09.2018 and 18.10.2019 respectively.

¶34

Pursuant to the request of the defendants for Term Loan (GECL) for Rs.9.60 Lakh, the applicant bank sanctioned the said TL of Rs.9.60 Lakh on 29.06.2020 on various terms and conditions, as stipulated in the sanction letter, which were duly accepted by the defendants. To secure the loan facilities defendants have executed various loan and security documents

¶35

Pursuant to the request of the defendants for GECL loan for Rs.7 Lakh, the applicant bank sanctioned the said TL of Rs.7 Lakh on 06.11.2021 on various terms and conditions, as stipulated in the sanction letter, which were duly accepted by the defendants. To secure the loan facilities defendants have executed various loan and security documents.

¶36

The defendants have also availed the Kisan Mitra Credit Card (KMCC) loan of Rs.50,000/-, which was sanctioned by the applicant bank on 04.08.2022.

¶37

After availing the sanctioned credit facilities, the defendants became irregular in repayment of their dues as per agreed terms and failed to adhere to the financial norms of the bank and avoiding the repayment of its dues to the bank, in spite of several assurances given by it to the applicant bank resulting in the account turning as NPA on 10.04.2023 .

¶38

Since, the defendants failed and neglected in spite of several reminders to make payment of the dues recoverable to the bank, hence this application has been filed by the bank.

¶39

#
b,
Presiding Omcer
Debts Rec)v 3 ry Tribunq
PA'FigA

OA 277 of 2024jJ1

DRT, PATNA

The total liability in the loan account is Rs.67,90,922/- as on 04.04.2024 with pendente-lite and future interest contractual rate from 05.04.2024 till the realization.

¶44

This Tribunal issued summons/notices copies of application & paper book to the defendants by registered/speed post on 03.07.2024, requiring them to show-cause within 30 days of the service U/s 19 (4) of the Act & Rule of the DRT [Procedure] Rules, 1993 .

¶45

In response to the notice the defendant no. 2 has appeared by filing vakalatnama on 12.07.2024. Despite the service of registered summons/notices, the defendant no. I & 3 have not appeared before this Tribunal to contest the case. The sufficient time has been given to them to defend the case, but they failed to appear and to file WS, hence, the Tribunal has passed an order to proceed ex-parte against them on 01.04.2025 .

¶46

Since the defendant no.2 has not filed written statement within the statutory period hence vide order dated 01.04.2025, opportunity to file the same was closed.

¶47

To prove its case, the applicant Bank has referred various certified photocopies of documents before this Tribunal. The applicant bank has also given evidence on affidavit by way of affidavit by Shri Saurabh Kumar, Branch Manager of the applicant bank. The details of documents are as follows :

¶48

Description Documents Photocopies of	of 1Date Execution	IAmount (in Lakh)	ISignature Executants of	1Ex./ Ann No
Loanapplication	11.09.2013	4.00	Def.no.1&2	1
credit Cash agreement	11.09.2013	4.00	le	2
mr	11.09.2013	4.00	Def.no.I&2
BPDRa lent	11.09.2013	4.00	Def.no.1&2
Guarante; IInent a	11.09.2013	4.00	Def.no.3
letter	11.09.2013	4.00	me
Declaration	11.09.2013	4.00	Def.no.3
Letterofrenewal	08.08.2014	4.00	Def.no.I&2

¶49

/r--

¶50

¶51

Presiding Debts R6cove t x'l:N A

OA 277 of 20241JI

DRT, PATN A

9	Supplemental agreement	08.08.2014	8.00	Def.no.1&2	9
10	I	08.08.2014	8.00	Def.no.1&2	10
11	Pronote	08.08.2014	4.00	Def.no.I&2	11
12	Guarantee agreement	08.08.2014	8.00	Def.no.3	12
13	coverIng I letter	08.08.2014	e		13
14	Declaration	08.08.2014	8.00	Def.no.3	14
15	BPDR	08.08.2014	8.00	Def.no.I&2	15
16	Letter ofrenewal	19.05.2015	12.00	Def.no.I&2	16
17	Supplemental agreement	19.05.2015	20.00	Def.no.I&2	17
18	Linkletter	19.05.2015	20.00	Def.no.I&2	18
19	Pronote	19.05.2015	12.00	Def.no.1&2	19
20	Guarantee agreement	19.05.2015	20.00	Def.no.3	20
21	coverIng I letter	19.05.2015	e		21
22	Declaration	19.05.2015	e		22
23	BPDR Agreement	19.05.2015	e		23
24	Letter evidencing depositof titledeed	19.05.2015	e		24
25	PhM) deed of sale	29.03.2014			25
26	Letter ofrenewal	16.06.2016	e		26
27	Supplemental agreement	16.06.2016	e		27
28	I	16.06.2016	30.00	Def.no.I&2	28
29	Pronote	6 =	ITO	Def.no.I&2	29
30	Letterofundertakin!	16.06.2016		Def.no.1&2	30
31	Draft of LEDTD	16.06.2016	30.00	Def.no.1&2	31
32	Guarantee	16.06.2016	30.00	Def.no.3	32
	agreement
33	Guarantee letter coverIng	16.06.2016	e		33
34	Declaration	16.06.2016	30.00	De£no.3	34
35	BPDRagreement	16.06.2016	30.00	Def.no.1&2	35
36	e ofdebt	11.06.2016		Def.no.I&2	36
37	Acknowledgement ofdebt	16.06.2016		Def.no.1&2	37
38	Letterofrenewal	19.07.2017	e		38
39	Supplemental agreement	19.07.2017	e		39
40	I	19.07.2017	48.00	Def.no.I&2	40
41	Pronote	19.07.2017	18.00	Def.no.1&2	41
42	Letter ofundertakinj	19.07.2017	48.00	Def.no.1&2	42
43	DraBof LEDTD	18.07.2017	48.00	Def.no.I&2	43
44	Guarantee agreement	19.07.2017	48.00	Def.no.3	44
45	Gt letter	19.07.2017	e		45
46	Declaration	19.07.2017	e		46
47	Letter of	28.09.2018		Def.no.1&2	47

¶56

D ebT: T:r T :bq 4 :: tr1[1d

OA 277 of20241JI

DRT, PATN A

48	lroDrietorshi- e	28.09.201	e			48
49	-uarantor	28.09.2018	e			49
50	me lroDrietorshi o		e			50
51	Letter ofrenewal		48.00	Def.no.1&2		51
52	Sanction letter	18.10.2019	48.00	Bank accepted def.no.1&2	ma by
53	Letter :uarantor		48.00	Def.no.3		53
54	Sanction letter	29.06.2020	9.60	a accepte def.no.I&2	dby
55	Take delivery letter toDPN	29.06.2020	9.60	e
56	Draft of LEDTD	29.06.2020	e			56
57	BPDRagreement	29.06.2020	e			57
58	1 agreement	29.06.2020	e			58
59	letter	29.06.2020	e
60	Declaration	29.06.2020	e			60
61	Letter of	17.09.2021		Def.no.1&2		61
	>roDrietorshi
62	Request letter for OD facility	17.09.2021	e			62
63	Sanction memorandum	17.09.2021	48.00	Bank accepted defno.1&2	ma by
64	Pronote	17.09.2021	48.00	Def.no.1&2		64
65	Letter uarantor r		48.00	Def.no.3		65
66	Declaration	17.09.2021	e			66
67	Letterofundertakin!	17.09.2021		Def.no.1&2		67
68	BPDR	17.09.2021	e			68
69	Acknowledgement ofdebtandsecurity	17.09.2021		Def.no.1&2		69
70	Request letterfor disbursement	06.1 1.2021	7.00	e
71	Agreement ofdeed cumhyDothecation	06.11.2021	7.00	Def.no.1&2		71
72	ma memorandum	06.1 1.2021	7.00	Bank accepted def.no.I&2	na by
73	Undertaking letter	06.1 1.2021	7.00	Def.no.1&2		73
74	Pronote	06.11.2021	7.00	Def.no.1&2		74
75	Take deliveryletter toDPN	06.1 1.2021	7.00	Def.no.1&2		75
76	Letterofundertakin!	06.1 1.2021	7.00	Def.no.I&2		76
77	e accounts			Bank		77

¶61

8 Heard arguments and perused the case record.

¶62

¶63

¶64

h„laIng oncet Debb Recovery Tribunal PATNA

OA 277 of2024jJI

DRT, PATN A

Ld. Counsel of applicant bank submitted that the defendants have taken the loan and utilized the same and also executed the various loan documents to secure the loan. Further, submitted that the claim of the bank has been proved by documentary evidence. All the transactions were entered in the ledger of the loan accounts in the name of the defendant duly maintained by the applicant bank in its usual course of business. The interest /compound interest has been charged at such rates, and capitalized at such periodical rests as are permitted by and do not run counter to the directives of Reserve Bank of India.

¶69

It is further submitted by Id. Counsel of applicant bank that there is no stay granted by any Higher Court, in respect of the proceedings of the present OA and requested to issue recovery certificate, as claimed for, in OA.

¶70

It has been established that defendants are living and carrying on their business in the state of Bihar. Cause of action also arose in the State of Bihar. The said claim on the date of filing of application exceeded Rs.20 lacs. The applicant bank is functioning within the jurisdiction of this Tribunal. Therefore, this Tribunal has territorial as well as pecuniary jurisdiction to adjudicate upon the present application.

¶71

On the issue of Limitation, to prove it, the applicant bank has submitted that the applicant bank has declared the account as NPA on 10.04.2023, whereas the present application has been filed on 15.05.2024. Even, it is counted for the purpose of Limitation, then it is established that the applicant bank has filed the case within the limitation period. As such, it is established that the present application has been filed well within the period of limitation.

¶72

13 . Shri Saurabh Kumar, Branch Manager of the applicant bank has filed the affidavit in support of contents of application and the documents as evidence and proved on oath the pleadings and documents of the applicant bank as stated above.

¶73

Section 19(3) of the Recovery of Debts and Bankruptcy -Act, 1993 provides that the application u/s S.19 (1) shall be accompanied with true copies of all the documents relied on in support of the claim.

OA 277 of20241JI

DRT, PATN A

The rule 12 (10) of the Debt Recovery Tribunal (Procedure) Rules, 1993, provides that if the defendant denies his liability to pay the claim made by the applicant, the tribunal may act upon the affidavit of the applicant who is acquainted with the facts of the case or who has on verification of the record sworn the affidavit in respect of the contents of the application and the documents as evidence.

¶79

The rule 12 (11) of the aforesaid Rules, provides that the provisions contained in section 4 of the Banker’s Books evidence that Act, 1891 (18 of 1891) shall apply to a certified copy of an entry in a Banker’s Books furnished along with application filed under sub section 1 of section 19 by the applicant.

¶80

Section 4 of Banker’s Books evidence Act, 1891 runs as underS.4. Mode of proof of entries in bankers’ books.–Subject to the provisions of this Act, a certified copy of any entry in a banker’s book shall in all legal proceedings be received as prima facie evidence of the existence of such entry, and shall be admitted as evidence of the matters, transactions and accounts therein recorded in every case where, and to the same extent as, the original entry itself is now by law admissible, but not further or otherwise.

¶81

As such the certified true copies of the doCuments are admissible in evidence. The statement of account maintained in the ordinary course of business is not only admissible but shall be taken as the correct statement of account, more so since the entries in the statement of account have not been challenged.

¶82

On perusal of the application, documents, affidavit and on consideration of the arguments, it is proved that the defendants have applied for loan and the bank had sanctioned the loan and to secure the loan and for repayment of loan amount with interests etc., the defendants have executed various loan documents, as stated in the application and proved by aforesaid evidence. Defendants have neither denied the utilization of funds advanced by applicant bank nor have pointed out any specific error and discrepancy in the Statement of Account.

¶83

The evidence discussed above goes to establish that the amount of loan as mentioned in the O. A., was availed by the borrower under the agreed terms and conditions for repayment with interest. The balance amount till 04.04.2024 has been proved to be Rs.67,90,922/- only by way of statement of accounts. There is nothing to prove the amount more than that disclosed in the aforementioned statement. As such this amount is recoverable till full and final realization of the claim.

¶84

Ifhq Presiding Omen Debb Recovery Tribunal P A " J l\

OA 277 of 2024jJl

DRT, PATN A

In my view, facts of the case stand proved by evidence of the applicant bank. Accordingly, the applicant bank is entitled to recover from defendants jointly and severally of Rs.67,90,922/- along with pendente-lite and future interest @ 10% p.a. simple from 15.05.2024 (The date of filing of this OA) till realization. So the final order may be passed accordingly, to meet the ends of JustIce.

¶89

ORDER

¶90

In the result, the application of the applicant bank is allowed and debt is determined with costs against the defendants. The defendants are hereby jointly and severally, ordered to pay the applicant bank its debt amounting to Rs.67,90,922/- along with pendente-lite and future interest @ 10% p.a. simple from 15.05.2024 (The date of filing of this OA) till realization of the entire sum due and recoverable with costs.

¶91

It is made clear that any amount deposited by the defendants, be deducted in the claim amount, if not deducted.

¶92

Defendants are debarred from transferring, alienating encumbering or otherwise dealing with or disposing of the mortgaged or hypothecated or any other properties and assets without paying the aforesaid adjudicated dues to the applicant bank to secure the ends of justice. The mortgaged or hypothecated assets to secure the loan in question are hereby attached and shall be subject to the final order under the recovery proceedings in pursuance of the Recovery certificate issued under Section 19(22) of Recovery of Debts and Bankruptcy Act 1993. The applicant may submit the certified copy of this Judgment and the Recovery Certificate before the Registrar/Sub- Registrar to endorse the charge over the secured assets.

¶93

Let a certificate of recovery be drawn up forthwith and put up for signatures in terms of provisions contained in Section 19(22) of the Act to be issued, on the basis of the order of the Tribunal to the Recovery Officer. The Recovery Officer shall realize the amount as per the certificate in the manner and mode prescribed under the Act from the defendants, by sale of mortgage(1/ hypothecated assets as well as other personal movable/immovable assets of the defendants. The Recovery Officer will issue demand notice to the Certificate

¶94

-- k„\ PresIding Often Debt, ':c:1--3ry Tribune PA' fN A

OA 277 of 2024jJ]

DRT, PATNA

debtors only after the proof of compliance under rule 16 of DRT (Procedure) Rules 1993, is submitted. The copy of this judgment be uploaded in the website of the Tribunal.

¶99

Parties are directed to appear before the Recovery Officer, DRT, Patna on 13.10.2025. The order be communicated accordingly.

¶100

Judgment signed, sealed, dated and pronounced in the open court on 03Fd day of September, 2025.

¶101

}\ a r\

¶102

Dictated &corrected by me.

¶103

[KaushalendraYadav] - Presiding Officer Debts Recovery Tribunal, Patna

¶104

D eb : : :1 :it!! T = =tX1E1baI

¶105

FORM NO, 9 [See Regulation 24( 1 )]

¶106

DEBTS RECOVERY TRIBUNAL PATNA

¶107

2nd Floor, (A. B & F Wing) Karpuri Thakur Sadan, Kendriya Karamchari Parisar (GPOA), Ashiana Digha Road, Patna-800025.

¶108

RECOVERY CERTIFICATE UNDER SE(,'TION 19(2) READ WITH SECTION 19(B) OF THE RECOVERY OF DEBTS & BANKRUPTCY ACT, 1993, AS AMENDED FROM TIME TO TIME.

R(,' No. 259/2025 IN

Case No: OA/277/2024

In the Matter of:

(CH- 1) CANARA BANK LAKHISARAI BRANC Il, PO- LAKHISARAI, PSKAWAIYA

¶113

Applicant(S)

¶114

LAKHISARAI,BIHAR -8 1 1311

¶115

¶116

(CD- 1) M/S SWAM TRADING

¶117

a proprictorship concern through its Proprietor Arati Devi, Wife of Shyam Kumar Vcrma, at Pachna Road, Bypass Road, Lakhisarai, PO- Lakhisarai, PS- Kawaiya, Lakhisarai,BIHAR -841435

¶118

(CD- 2) ARATI DEVI

¶119

W/0- SHYAM KUMAR VERMA. R/0- PACHNA ROAD. SANKAR POKHAR, LAKHISARAI. P.0.LAKHISARAI, P.S.- KAWAIYA, DISTRICTLAKHISARAI,

¶120

Defendant(s)

¶121

(CD- 3) SHYAN[ KUMAR VERNIA

¶122

S/0- SOPENDRA PRASAD VERMA, R/0- PACHNA ROAD, SANKAR POKHAR, LAKHISARAI, P.0.LAKHISARAI. P.S.- KAWAIYA. DISTRICT-

¶123

LAKHISARAI,

¶124

Recovery Certificate for Rs 6790922,00 [ Rupees Sixty Seven Lakhs Ninety Thousands Nine Hundred TWenty TWo OnI}=1

¶125

In terms of final order dated 03/09/2025 passed by this Tribunal in the above mentioned case, it is ordered that the Applicant Certificate Holder Bank is entitled to recover a sum of Rs. 6790922.00 along with cost, expenses and interest from the 1 5/05/2024 i.e. date of filing / with effective date of the OA/277/2024 and future interest from order date till the date of realisation in full, jointly or severally from the Certificate Debtors, hereinafter referred to as:-

¶126

,noI CDName Type	Int. ! Rate	iEffective Date
M/S SHYAM ING	10	5/05/2024	lyAnd	lterest As
	10	llS/05/2024
IYAM KUMAR ERMA	10	F15/05/2024

¶127

In case of failure to pay the aforementioned adjudicated amount within 30 days, same shall be recovered from the sale of the mongaged/hypothecated assets as well as other personal movable/ Immovable assets of the certificate debtors

¶128

The mortgaged or hypothecated assets to secure the loan in question are hereby attached and shall be subject to the final order under the recovery proceeding in pursuance of the Recovery certificate issued under Section 19(22) of Recovery of Debts and Bankruptcy Act 1993.

¶129

Parties are directed to appear before MANOJ KUMAR , Recovery Officer, DEBTS RECOVERY TRIBUNAL PATNA on 13/10/2025.

¶130

The Recovery Officer shall realize the amount as per this Certificate in the manner and mode prescribed under Sections 25 to 28 of the Recovery of Debts Due to Banks and Financial Institutions Act, 1993 (as amended from time to time) from the above named Certificate Debtors.

¶131

This Certificate has been issued under my signature and seal of the Tribunal on this 08/09/2025

¶132

Gb. DEBTS RECOVERY TRIBUNAL PATNA„„k
Registrar
Debts Recovery Tribunal P?llsiding Oficer
Patna Debts Recover/ Tribunw
PATNA

¶133

FORM NO. 10 [See Regulation 24(2)]

¶134

DEBTS RECOVERY TRIBUNAL PATNA

¶135

2nd Floor, ( A. B & F Wing) Karpuri Thakur Sadan, Kendriya Karamchari Parisar (GPOA), Ashiana Digha Road, Patna-800025 .

¶136

SCHEDULE TO RECOVERY CERTIFICATE MEMO OF COSTS

RC No. 259/2025

Case No: OA/277/2024

Applicant(s): CANARA BANK

¶141

Versus

¶142

Defendant(s): M/S SHYAM TRADING

¶143

Item ofCosts	lount inRs
'eeon the application	m7
ProcessFees(Inc. Publication)	Fo
AdvocateFees	ro
	-P
MiscellaneousCharges	[0
Total Costs:Rs	m7

Place: PATNA

PRESIDING OFFICER

Date: 08/09/2025

DEBTS RECOVERY TRIBUNAL PATNA

¶149

Note: Strike out whichever is not applicable

¶150

D eb: :: :::(!IF ; : ::tEIIIIII!I)

Canara Bank v. M/s Shyam Trading

Case brief

What is this about?

What did the court decide?

Canara Bank v. M/s Shyam Trading

Case brief

What is this about?

What did the court decide?

What the court decided

A compact analysis

Issues for consideration

Statutes considered

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Case details

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