(4) It is stated in the reply that at the very outset the answering respondents deny all the allegations, contentions and averments stated in the application filed by the applicant except to the extent it is expressly admitted therein and the applicant is put to strict proof of the allegations, contentions and averments not specifically admitted herein; that the non-traversal of any paragraph should be read as categorical denial; that the present application was filed against the answering respondents which in fact is not maintainable because no legal right of the applicant has been violated by the answering respondents; that answering respondents has sanctioned the loan to respondent No. 3 after going through the original documents and in due diligence and moreover, the loan sanctioned by the answering respondents is prior in date and therefore, answering respondents have first charge over the secured property; that all the actions taken by the answering respondents after the proper compliance of procedure as mentioned in the Act, and Security Interest (Enforcement) Rules, 2002; that the applicant has attempted to misguide and mislead this Hon’ble Tribunal and has concealed the material facts from this Hon’ble Tribunal; that the answering respondent has appointed Mr. Nehil Jindal, Chief Manager, Indian Bank presently posted at Chandigarh, who is well conversant with the facts of the case and is in a position to depose about the facts of the case; that respondent No.3 has approached the answering respondent for sanction of loan of Rs.15,00,000/ and
