Case of Ujwal Gupta vs Union Bank of India, NCLAT Delhi Judgement Dated 7th January 2026. The appellate tribunal held that a demand notice under section 13(2) of the SARFAESI Act can constitute a valid invocation of a personal guarantee under the IBC. The tribunal held that the substance of the notice matters more than its label, and addressing the guarantor as a “director” does not invalidate the invocation if the intent to claim dues is clear.