circle rates are a factor in property valuation under the SARFAESI Act, they are not the sole determinant of fair market value, especially in public auctions.

2)A public auction sale, even if below the circle rate, is generally considered valid because it reflects the open market price at the time of the auction. 

3) Division Bench at Calcutta Court in Ballyfabs International Limited v. State of West Bengal (2022) ibclaw.in 97 HC held that once the sale is effected by an authorized officer under SARFAESI Act by making wide publication in the widely circulated newspapers, shall be regarded as the open market sale and, therefore, the registering authority cannot have any reason to believe that the sale price has been shown under-valued having not sold in the open market.

It is no doubt valid to purchase property for less than the circle rate in a bank auction sale, as long as the sale price is not less than the reserve price set for the auction. 

However, the purchase can be challenged in the Debts Recovery Tribunal (DRT) under specific circumstances, such as fraud, collusion, or failure to follow due process. 

The circle rate (also known as guidance value or ready reckoner rate) is the minimum value at which a property can be registered, whereas the reserve price is the minimum price at which a bank is authorized to sell a property in an auction. 

If the auction price is equal to or above the reserve price, the sale is generally considered valid, even if it's below the circle rate.

If the value determined by the valuation officer is less than the circle rate, the value would be regarded as the sale price.

If the valuation officer determines a value that is higher than the circle rate, the circle rate would be regarded as the sale price.

The circle rate prescribed by the Government is for the purpose of the calculating stamp duty and registration fees.

The market price on many occasions may not match with the circle rate. 

Judgement require careful and detailed study of your case otherwise same can go against you 

have already provided judgment on the issue 

There is no direct judgement pertaining to your query, besides the judgments are of no use in this preliminary stage, however since many experts have provided you some judgments, you may go through them and if you are not satisfied then you can approach your own advocate for finding a suitable judgment.

You need to seek consultation and explain the matter in detail 

These judgments ate not available online 

Te referred citations cannot be found either in the internet or any other online mode.

You may approach your own advocate for searching suitable citations.

You can try on Google search or in website of the said courts 

Most DRT/DRAT judgments are not available online. You can:

• Check on https://edrt.gov.in (login required)

• Visit or contact the concerned DRT Registry (e.g., DRT Raipur) for case documents

• Use SCC Online, Manupatra, or Indian Kanoon for High Court/Supreme Court cases

Key Supreme Court Judgments:

1. Mathew Varghese v. Amritha Kumar (2014) 5 SCC 610 – Auction must follow due process

2. Ram Kishun v. State of UP (2012) 11 SCC 511 – Sale below circle rate can be unfair

3. Sri Siddeshwara Co-op Bank v. Ikbal (2013) 10 SCC 83 – Undervaluation can be challenged