The Bombay High Court in Tata Motors Finance Solutions Ltd. v. Naushad Khan held that a financial institution under the Recovery of Debts and Bankruptcy Act, 1993 is mandated to approach the Debt Recovery Tribunal for adjudication and crystallisation of debt due. Arjun Gupta and Shruti Dhonde from the International Dispute Resolution and Investigations Team at Nishith Desai Associates, discuss the practical implications of this judgement on agreements for investment into listed debt securities.