Recovery of 25k transferred by your friend in 2016 is now time barred. That is, out of limitation, he should have approached Court within three years. But if he files a case for recovery of 25K you will be entitled to file a counter claim of 36K due to him after adjusting 25 K against 61K. It is to your advantage if he goes to Court as that will review you claim of 36K. Let him go to Court after that you file counter claim for 36k.