Section 26E of the SARFAESI Act came into force only on 24.01.2020; and there was no law before these amendments to give priority to the secured creditor over other debts - right to enforce the secured debt accrues only upon default by the borrowers and after realisation of the dues by the Income Tax Department.

 Ms.Tanya Kapoor, learned counsel for the respondents 5 to 8
would submit that Section 26E of the SARFAESI Act came into force only on
24.01.2020; and there was no law before these amendments to give priority to the
secured creditor over other debts. In this context, the learned counsel placed
reliance on the decision of the 

Chattisgarh State Co-operative Marketing
Federation Limited v. Bank of Baroda 

[2020 SCC ONLINE Chh 1271] 

and
contended that the Central Government issued notification dated 26.12.2019 and
Sections 17 to 19 of the SARFAESI Act came into effect. Therefore, there was
no law before these amendments giving priority to the debts of the secured
creditor. The learned counsel further submitted that the appellant's right to
enforce the secured debt accrues only upon default by the borrowers and after
realisation of the dues by the Income Tax Department.