On writ, the High Court held that, in the absence of a specific statutory provision to the contrary, the dues of a secured creditor have priority over Government dues. In the present case, the hypothecation agreement in favour of respondent No. 3 was executed on 12-12-2008, much prior to the issuance of the prohibitory order by the Tax Recovery Officer under S. 222, and therefore the secured creditor was entitled to enforce its security and sell the assets. Though the Revenue had issued a prohibitory order, it took no further steps for recovery and cannot keep the properties attached indefinitely. Despite being duly informed at every stage about the proposed and completed auction, the tax authorities neither raised objections nor initiated proceedings to challenge the sale, thereby indicating acquiescence. Accordingly, the attachment order could not be construed as an impediment to the auction sale in favour of the petitioner, the secured creditor’s claim having precedence over the Revenue’s claim. Reliance was placed on Dena Bank v. Bhikhabhai Prabhudas Parekh & Co 2000) 5 SCC 694., Stock Exchange, Bombay v. V.S. Kandalgaonkar, (2014) 271 CTR (SC) 192 : (2014) 109 DTR (SC) 225 : (2015) 2 SCC 1  UOI  v. N. Murugesan (2022) 2 SCC 25  and State Bank of India v. M.J. James. (2022) 2 SCC 301.