In Femina Developers Ltd v Indiabulls, the doctrine of election on the claim of remedy under the NPA Act and the RDB Act, 1993 was under challenge. The Delhi high court held that the NPA Act is an additional remedy to the RDB Act, which together constitute a single remedy, rendering the doctrine inapplicable. In MD Frozen Food Export Pvt Ltd v Hero Fincorp Ltd held that the secured creditor can go for the claim of recovery against the debtor before different forums under the Arbitration Act if the secured assets are insufficient to satisfy the debt. In Mathew Varghese v M Amritha Kumar, the court held that the provisions of the SARFESI Act and the RDB Act are complimentary to each other.