$~107 * IN THEHIGH COURTOF DELHIAT NEW DELHI # CNR No. DLHC010325572026 + W.P.(C) 10139/2026 & CM APPL. 47077/2026 SEASONAL SEED PVT LIMITED .....Petitioner Through: Mr. N Hariharan, Sr. Adv. with Mr. Sacchin Puri, Sr. Adv. with Mr. Arun Khatri, Ms. Charu Sharma, Mr. Krish Mahajan, Advs. versus PINE LABS LIMITED AND ANR & ANR. .....Respondents Through: Ms. Gurmeet Bindra, Adv. for R-1 Mr. Abhishek Baid, Mr. Mohit Kumar Bafna, Mr. Praneet Das and Mr. Ravinder Kumar, Advs. for R-2 CORAM: HON'BLE MR. JUSTICE JASMEET SINGH O R D E R % 05.08.2026 1. This is a writ petition filed under Article 226 of the Constitution of India seeking the following prayers: - “a) Issue an appropriate writ, order or direction directing Respondent No. 1 to forthwith release and remit the Petitioner's wrongfully withheld merchant settlement amounts and to remove the arbitrary restriction on the settlement of funds pertaining to the Petitioner's Merchant This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 17/08/2026 at 11:55:23 Account maintained with Respondent No. 1. b) Issue an appropriate writ, order or direction directing Respondent No. 2 to take appropriate action in accordance with applicable provisions, circulars and guidelines issued by the Respondent No. 2, and to ensure that Respondent No. 1 forthwith releases the Petitioner's wrongfully withheld settlement amounts and processes future settlements in accordance with the applicable regulatory framework...” 2. The brief facts of the case are that the petitioner was onboarded by respondent No. 1 as a merchant for availing online payment aggregation and merchant settlement services under merchant ID No. 6339148, POS ID No. 4981728, TID No. 10000894 and MID No. 400100001005572. 3. The petitioner’s customer payments were processed through respondent No. 1 and settlement amounts were being remitted in the ordinary course of business.Respondent No. 1 started withholding petitioner’s merchant settlement amounts from 22.05.2026 onwards. 4. On protest by the petitioner, respondent No. 1 informed that certain transactions were flagged under a cyber complaint and therefore, the amounts were not being released. As per the petitioner, customer payment aggregating to Rs. 33,47,52,353.56, had been received by respondent No. 1 out of which Rs. 27,91,28,532.00 have been remitted to the petitioner while a sum of Rs. 5,56,23,821.56 continues to be withheld by respondent No. 1. 5. Ms. Bindra, learned counsel for the respondent No. 1, states that the investigating agencies have directed respondent No. 1 to debit freeze This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 17/08/2026 at 11:55:23 such sum present in the account and hence, the respondent No. 1 has withheld the amounts.Additionally, the respondent No. 1 has also received 946 charge back requests, aggregating to Rs. 1,69,32,213/-. 6. She further relies on the judgment of Hon’ble Supreme Court of India in the matter of S. Shobha v. Muthoot Finance Ltd, 2025 SCC OnLine SC 177, to urge that the grievance of the petitioner is against the respondent No. 1, which is a private entity and hence, the writ petition will not lie. 7. I have heard learned counsels for the parties. 8. In the present case, respondent No. 2 i.e., RBI is the statutory regulator entrusted with the supervision, regulation and oversight of payment systems and payment aggregators in India under the provisions of the Payment and Settlement Systems Act, 2007 and the regulatory framework issued thereunder, including the Guidelines on Regulation of Payment Aggregators and Payment Gateways. 9. Since the allegation of the petitioner is that the respondent No. 1 has not complied with the provisions of the aforesaid act, the present petition is maintainable. 10. The case of S Shobha (supra)does not aid the respondent No. 1 as the respondent in that case was an NBFC which did not possess the attributes of a statutory body despite being required to act under a statute. However, in the present case respondent No. 1 is authorized to operate as a payment aggregator only by virtue of such statutory and regulatory framework and is bound to comply with the directions, circulars and guidelines issued by respondent No. 2 from time to time. Hence, prima-facie, the writ petition will lie. This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 17/08/2026 at 11:55:23 11. In the present case, the petitioner is challenging the impugned action of respondent No. 1 in withholding amounts due and payable to the petitioner. 12. There is no credible basis for keeping a lien on entire amount of Rs. 5,56,23,821.56, when the amount in dispute is about Rs. 1,69,32,213/- (being the charge back request). Keeping a lien on the entire amount of Rs. 5,56,23,821.56, will work to the prejudice of the petitioner as the petitioner is required to meet its business requirements. Hence, the petitioner has demonstrated a prima-facie case and the balance of convenience also lies in favour of the petitioner. If interim orders are not passed today, the petitioner shall suffer irreparable loss and injury. 13. For the said reasons, the respondent No. 1 shall keep a lien on Rs. 1,69,32,213/- and Rs. 9800/- and release the balance amount in favour of the petitioner. 14. The petitioner shall also submit an affidavit/ indemnity bond that in case any further charge back is received by the respondent No. 1, the same shall be made good by the petitioner within 2 weeks of the demand being raised by respondent No. 1. On submission of the indemnity, within 2 days, the amount shall be remitted. 15. The petitioners are at liberty to avail of their legal rights for the balance amount in accordance with law. 16. The petition is disposed of. 17. The counter affidavit handed over in Court today is taken on record. JASMEET SINGH, J AUGUST 5, 2026/sp This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 17/08/2026 at 11:55:23