Relationship between Banker and Customer: A Legal Analysis of

Duty of Care in Indian Courts

Index of Contents

S. No Title Page No

1. Abstract 03 - 04

2. Introduction 04 - 05

3. Nature of the Banker–Customer Relationship 05 - 09

4. Judicial Interpretation of the Duty of Care 09 - 11

5. Digital Banking and Cyber Frauds 11

6. Role of RBI in Strengthening Duty of Care 12 - 13

7. Adequacy of Current Laws and RBI Guidelines 13 - 14

8. Findings 14

9. Suggestions and Recommendations 14 - 15

1
 10 Conclusion 15

11 Bibliography 15

Relationship between Banker and Customer: A Legal Analysis of Duty of

1. Abstract

The banking activities in India are based on the association between the banker and a
customer. This relationship is primarily subject to the rules of contract law as provided in the
law. When an individual opens an account, a contract is established, which is formal, and this
contracts the banks to some responsibility. The duty of care is one of the most crucial duties.
This implies that the banker has to be careful, truthful and reasonably skilled in handling the
money and the instructions of a customer. The position of the banker extends beyond the
simple paradigm of debtor-creditor, and that of agent, trustee, or advisor to the service being
offered, specifically.

The research questions of this paper are as follows: To investigate what particular
responsibilities of care Indian banks have towards their customers and how Indian courts can
identify whether a bank has been negligent in the case of forged cheques, mishandling of
accounts, locker activities, and online transactions; and whether the current legal system, in
terms of their current laws and regulations provided by the RBI, suffices in the protection of
their customers against any banking errors, fraud and risks occurring within the modern
digital banking channel or additional reforms are necessary to be provided to make Indian
banks more customer-focus

2
The proposed research follows the doctrinal approach to research mainly through
interpretation and analysis of the law sources. It entails the review of the statutory regulations
found in the Banking Regulation Act, 1949, Negotiable Instruments Act, 1881, the Indian
Contract Act, 1872, Information Technology Act, 2000 and other guidelines issued by the
reserve bank of India. The paper also examines judicial decisions made by the courts in India,
and the decisions made in other jurisdictions, to know how the relationship between a banker
and a customer has been construed and the determination of liability in cases of negligence.
Besides primary legal sources, secondary sources are also consulted like academic books,
journal articles, commentaries and law commission reports to assist in offering academic
insight. The study under consideration comprises a critical analysis based on logical
arguments, comparative analysis, and case study in order to make sound conclusions on the
topic of the duty of care of banks under the Indian legal system.

The Court in Canara Bank v. Canara Sale 1Corporation held that banks ought to create
identities of the customers, maintain customer information as confidential, and conduct
transactions with care. Courts can impose the negligence on the banker in case he or she does
something trivial such as encashing a cheque that is forged or giving wrong advice. In such
cases, the damages can be refunded by customers, i.e. it can be said that the bank is liable to
recompense any loss suffered by it as a result of its negligence. Although the courts have in
many instances reiterated that banks have a duty to anticipate such risks and proactively
avoid losses, they do not hold them responsible in case of unexpected misconduct by third
parties or the culpable consumers.

The judges use such legal standards as the reasonable banker test in order to find out whether
a bank was prudent in its conduct. The guidelines do not require perfection by the bank but
care and caution. The other statutory requirements such as the Banking Regulation Act and
regulations established by the reserve bank of India, add more requirements and helps the
courts in establishing whether the requirements were met.

At other moments, the bank is an agent (and so on collecting cheques) or trustee (and
keeping goods in a safe deposit box) and the measure of the duty varies with the relation.
Indian courts have a tendency to support customers in case terms of contract of a bank are not
clear or where a bank undertakes an activity which results in loss, which shows their concern
in safeguarding the consumer.

1
Canara Bank v. Canara Sales Corp., (S.C. India Apr. 22, 1987), 1987 AIR 1603, 1987 SCR (2) 1138

3
In brief, one of the significant legal duties in the relationship between a bank and its client is
the duty of care. It is what holds trust in the financial system, safeguards customers against
harm as well as makes the banks respect the law. Indian courts have remained significant in
establishing the meaning of this duty and ensuring that the banks fulfil their obligation

2. Introduction

The very existence of all banking affairs is based on the legal and business relationship that is
shared between a banker and a customer. This relationship although based on a contract is
more than a contract and has aspects of trust, confidence and statutory responsibility. Where a
customer deposits money or avails the banking services, the bank owes an obligation to act in
reasonable skill, care and diligence. This is an expectation that has intensified grossly over
the past few decades when the banking scene has taken on a new complex form of operation,
beyond cheques, to a digital platform, real time money transfer, investment broker, and online
financial services. Not only has the shift increased the range of services, but also the
magnitude of the potential risks increases, making the duty of care more important than ever.

In India, judicial interpretation has been used extensively to formulate much of the
knowledge on the duty of care of a bank as opposed to a single codified law. It has always
been stressed by the courts that banks should be very careful especially in issues like
checking signatures, avoiding fraudulent withdrawals, lockers, keeping the information about
their customers a secret and acting in accordance with the regulating policies. The judicial
declarations have strengthened the idea that banks are in a financial responsibility position
and they must anticipate and reduce risks that may be detrimental to the customers. But the
soaring levels of cyber fraud, phishing attacks, data breaches, and automated banking
mistakes have thrown up some urgent questions as to whether the traditional principles of law
are sufficient to apply to the modern banking realities.

That is why it is necessary to discuss the way Indian courts think about the duty of care now
and whether the current mix of legislation, jurisprudence, and regulations suggested by RBI
is enough to ensure that consumers are safe in a more digitalized world. The study examines
the legal framework in place in banker-customer relationship, critical cases in the courts and
case on the changing nature of the bank liability in the modern financial systems. Finally, the
paper aims at establishing the need to reform in order to enhance consumer protection and
accountability in the fast-changing banking system in India.

4
 3. Nature of the Banker–Customer Relationship2

The relationship between banker and customer is not uniform; its nature depends on the type
of service offered. Indian courts have recognised several dimensions of this relationship:

Debtor–Creditor Relationship

The most fundamental relationship is that of debtor and creditor, as recognised in the English
case Foley v. Hill (1848)3, which Indian courts continue to cite. When customers deposit
money, ownership transfers to the bank, which becomes their debtor. Conversely, when a loan
is granted, the customer becomes the debtor.

This relationship forms the basis of banking operations, yet banks must perform their
obligations with due care. For example, ensuring proper withdrawal procedures and
preventing unauthorised transactions.4

Banker as Agent

Banks are agents when they receive cheques, issue payments on behalf of the customer or
perform standing instructions. In this situation, the bank has the responsibilities as an agent
under the Indian Contract Act, Section 182-238, which is due diligence and accountability.

Agent-based roles include:

a) Collection of Cheques and Drafts

A bank is an agent of the customer when the bank receives cheques or demand drafts on
behalf of a customer. The bank will have to appear to make payment of the cheque within a
reasonable time, endorsements, and proper clearing procedures. In case the bank has delayed
to collect or they are unable to notice anomalies like forged signature or poor endorsement,
then they can be liable to negligence. The bank has the responsibility of verifying, and
processing in time, which are the major aspects of the duty of care.

b) Payment of Insurance Premiums

2
Anjani Kant, General Relationship Between Banker and Customer 3–5,
[Link]
%20RELATIONSHIP%20BETWEEN%20BANKER%20AND%[Link].
3
Foley v. Hill, (1848) 2 H.L.C. 28, 9 Eng. Rep. 1002 (H.L.).
4
Expert Insights, Understanding the Debtor-Creditor Relationship, Wolters Kluwer,
[Link]

5
Banks are usually instructed by the customer to automatically pay insurance premiums using
standing instructions or direct debit. In this, the bank is an agent and therefore has to make
sure that payments are made in the correct time and manner. Inability to pay on time may
result into lapses within the insurance policy of the customer thereby causing him to lose the
cover. In case the delay is caused by negligence of the bank, the bank might be asked to pay
the customer.

C). Fund Transfers

Banks deal with funds transfer including NEFT, RTGS, IMPS, UPI, and intra bank transfer.
In the process, the bank has to authenticate the account details, the identity of the customer
and transfer of funds in a secure manner. Mistakes such as transfer of money to a different
account or not blocking fraudulent transfer can constitute negligence. The duty of care is an
obligation in which the bank is expected to exercise the right technology, security measures,
and be quick to reply to customer complaints.

d) Handling of Investment Instructions

The bank is supposed to take the instructions given by the customer literally when the
customer instructs his bank to invest the money in fixed deposits, mutual funds, government
securities or other forms. The bank should make sure that it is executed properly, that the
investments are not made without authorisation, and the risks related to it are clearly
presented. The fiduciary duty can appear in case the customers rely on the advice of the bank.
Loss of finances can result in liability of action due to failure to execute instructions properly
or due to misleading advice.

Banker as Trustee

When a customer puts the valuables like jewellery, important documents or any other
valuables in the safe deposit locker of a bank, the bank becomes a custodian or trustee of
those items. The locker services have the effect of increasing the fiduciary responsibility of
the bank compared to the traditional banking dealings that are more of a debtor-creditor or
agent-principal relationship. This implies that the bank needs to be more cautious so that
customer valuables are secure, of protection and can only be accessed by approved
individuals.5

5
Kuldeep Singh, Relationship Between Banker and Customer, 3 Int’l J. Trend Sci. Res. & Dev. 1535 (2019),
[Link]

6
Under this role, the bank is expected to keep a high standard of security, good inventory
records as well as adhere to a clear procedure whenever there is a locker assigned, forced or
opened. The bank will be supposed to guard the valuables of its clients as a prudent man
would guard his or her own valuables. Any negligence can be in respect of any failure in such
precautions, e.g. the failure to keep locker records, to grant unauthorised access or to break
open a locker without due notice.

The Supreme Court’s judgment in Amitabha Dasgupta v. United Bank of India (2021) 6 is a
landmark case in this area. The Court condemned the bank due to poor management of the
locker, loss of valuables and poor documentations. It believed that banks cannot invoke
immunity by claiming that lockers are run in independent mechanisms over which they have
no control. In its turn, the Court made it clear that banks have a positive responsibility to
provide the safety of lockers, to keep electronic and physical records and to implement the
strict security rules.

The Supreme Court was also of the opinion that there was general laxity in the locker
management by banks and therefore issued specific directives to the Reserve Bank of India
(RBI) to lay down the guidelines. Consequently, the present regulations demand that banks:

 Maintain updated locker registers and CCTV recordings,

 Breaking open a locker without informing the customers,

 Install biometrics and two key systems

 Provide excellent security of the locker premises, and

 Pay customer proven loss by negligence.

So, in the case of acting as trustees’ banks are subject to a much higher level of care. This
provides security to the valuables of customers and maintains the trust of people in locker
facilities as a secure form of custody.

Banker as Bailee

Under Sections 148–171 of the Indian Contract Act 7, a bank becomes a bailee when a
customer deposits goods or valuables for safe custody. Under this role, the bank must
exercise reasonable care of the items just like a prudent person would exercise care of his or

6
Amitabha Dasgupta v. United Bank of India, AIR 2021 SC 525.
7
The Indian Contract Act, 1872, No. 9 of 1872

7
her property. The bank should make sure that the articles are kept in a safe place, they are
guarded against theft, fire, damage or unauthorised persons. In the event that the bank does
not uphold the necessary security, or misplaces the goods, it can be found guilty of
negligence.8 The duty of care also involves proper documentation of the deposit, keeping of
custody records and only the rightful owner should get the items. The bank as a bailee will
not be exempted of the liability only because the goods were not always in its direct physical
possession. This task strengthens the confidence of customers in banks when they resort to
the safe custody services.9

Banker as Advisor or Fiduciary

Banks may exceed the scope of standard banking services and venture into the advisory
business when offering banking services like investment advice, portfolio management or
financial planning. Fiduciary element would be established in this case as the customers are
dependent on the higher knowledge, expertise and skill of the bank. Even though not all
advisory interactions form a fiduciary relationship, the courts explore the issue of customer
reliance on the judgment of the bank, and the discretionary influence of the bank. In case
such reliance is established, the bank should exercise the highest good faith, disclose all the
material risks, not give false statements and advice must be appropriate to the financial
situation of the customer. Any violation of these duties can be negligent misrepresentation or
breach of fiduciary duty. Banks may also be liable to courts in case customer losses arise as a
result of faulty advice, failure to disclose the risks or unauthorized investment decision. Such
an extra responsibility is a manifestation of the confidence that the customers have in banks
to advise them on financial issues.

4. Judicial Interpretation of the Duty of Care

The Indian courts have been hugely instrumental in forming, construing and broadening the
duty-of-care that banks should exercise towards their customers. Although there is some basic
guideline through statutory provisions, the actual meaning of responsibility of a bank in a
practical situation is determined through judicial interpretation. Courts consider each case
through the analysis of the behaviour that a reasonable banker should maintain and whether
the bank behaved with due diligence, skill and prudence. The judiciary, in many landmark

8
Banking School, Explained: Bailee-Bailor Relationship, Banking School (last visited Nov. 22, 2025),
[Link]
9
Bharath Narayan, Banker as a Bailee, Int’l J. L. & Legal Research (IJLLR) (last visited Nov. 22, 2025),
[Link]

8
cases, such as the forged cheque, haphazardly opened accounts, mismanaged lockers, and the
breach of confidentiality have made it very clear that the banks should employ stringent
verification measures and ensure high standards of operation. Apart from summarising what
defines negligence, these judicial rulings tell the banks the degree of caution they ought to
adopt in various varieties of transactions. With the changing digitalisation of bank activities,
courts are still developing the duty of care to meet the current issues of cyber fraud and
electronic transfer of funds. Therefore, the interpretation of the law by various courts is the
foundation of liability in banks, which involve the security of customers and the maintenance
of confidence in the banking sector

Negligent Encashment of Forged Cheques

Canara Bank v. Canara Sales Corporation (1987)10

The decision in Canara Bank v. Canara Sales Corporation (1987) is one of the most
significant judgments on banking negligence and safeguarding customer rights. The case
developed a settled law according to which a bank cannot debit the account of a customer
unless the customer authorizes it. Faked cheques do not qualify as valid mandates and thus,
all the transactions made based on this are unlawful. The decision has far reaching
ramifications on the banking business especially the clearing of cheques, internal security of
the business and redress of client complaints. It further reiterated that banks are not
professionals but custodians of the money and thus must be careful and honest with the
money.

Liability in Handling Lockers

Amitabha Dasgupta v. United Bank of India (2021)11

The Supreme Court ruled that the bank was responsible of opening the locker of the customer
without prior alert and loss of valuables. The Court condemned the bank in its bad
management of lockers and negligence in adhering to proper procedures. It held that the
banks are under obligation to make sure that lockers are secure and are properly handled. The
Supreme Court also instructed the Reserve bank of India (RBI) to come up with stringent and
encompassing guidelines on locker operation and safety to avoid such laxity in the future.

Customer Confidentiality

10
Canara Bank v. Canara Sales Corp., (S.C. India Apr. 22, 1987), 1987 AIR 1603, 1987 SCR (2) 1138
11
Amitabha Dasgupta v. United Bank of India, AIR 2021 SC 525.

9
State Bank of India v. Shyama Devi (1978)12

The evidence provided before the court in State Bank of India vs Shyama Devi was examined
and the legal principles of vicarious liability and responsibilities of a bank to its customers.
The court ruled and found the following:

A. Vicarious Liability: The court in the case determined that the bank is vicariously
liable due to the actions of its employees in case it was according to the scope of their
employment. In the case the bank is found liable to the losses as the unauthorised
transactions were proven to be supported by the negligence of the employees of the
bank.
B. Due Diligence: It was established by the court that the bank had not taken due
diligence to follow up on the transactions as well as to protect the account of the
customer. Absence of appropriate check and balances served in the incidence of
unauthorised transactions.

C) Compensation: The court ruled in favour of Shyama Devi, ordering the State Bank of
India to compensate her for the losses incurred due to the unauthorised transactions.
The amount of compensation was calculated on the level of financial loss incurred by
the customer.
D) Preventive Measures: The court further stated that banks should have strong security
measures and procedures to avoid such cases in future. The banks were encouraged to
put the safety and security of the customer accounts first so as not to lose the trust and
confidence of the banking system.

5. Digital Banking and Cyber Frauds

Cyber fraud has become one of the most difficult fields of both a customer and a bank due to
the introduction of new types of financial risks created by digital banking. The contemporary
patterns on judicial cases in countries tend to consider the liability of the bank in situations of
unauthorised electrical transfer, phishing, and UPI scams and data breaches. The judges tend
to impose liability on banks in cases when it is clearly seen that the bank has not put proper
security conditions, like effective authentication measures, real time fraud detection,
12
State Bank of India v. Shyama Devi, (1978) 3 SCC 399

10
encryption criterion or prompt linking of suspicious operations. When this occurs, it would be
the fault of the bank since the customers have a good expectation of secure digital platforms.
Nonetheless, the courts do not disregard the negligence of the customers in the case when the
people provide the sensitive information in the form of OTPs, PINs or passwords which
directly leads to the fraud.13 In this case, the liability of the bank can be capped down, since
the customer was involved in the loss. In other situations, the courts turn to the shared
liability technique particularly where the system of the bank and the actions of the customer
contributed to facilitating the fraud. This is a moderate position that maintains the fairness as
well as promoting vigilance on both sides. With the rising activities of digital transactions, the
responsibility of care has moved beyond the standard verification mechanisms of the banks to
the sphere of cyber vigilance, prompt identification of fraud, and deployment of sophisticated
technological solutions that would ensure that customer funds are safeguarded in the digital
space.

Customer Responsibility and Contributory Negligence

Although the courts in India are generally protective of the banking customers, they also do
agree that the customers do have some roles to play in protecting their own financial interests.
This fact is manifested in the principle of contributory negligence according to which the
liability of the bank may be decreased or restricted by the reckless conduct of the customer.
To illustrate, when a customer fails to report cases of fraud as promptly as possible, provides
personal data including OTPs or passwords, or signs empty cheques, the courts might be
convinced that the customer played a role in the loss. In the same way, the inability to adhere
to security rules provided by the bank or insufficient oversight of the workers in business
accounts can undermine the argument of the customer. In this eventuality, the courts can rule
that the loss not be shouldered on the bank, but they can be shared. 14 This will be a fair way
of doing it and will make the customers take basic precaution interacting with banking
systems. Indian courts more effectively ensure a safer, more responsible banking environment
through the equitable distribution of the responsibilities of both sides.

6. Role of RBI in Strengthening Duty of Care

The central banking institution, which is the reserve bank of India (RBI) is a key player in
establishing, controlling, and enforcing the duty of care banks have towards their customers.
13
Kumudha Rathna, Online Banking Fraud in India, Int’l J. Trend Sci. Res. & Dev. (IJTSRD) 295 (Dec. 2016),
[Link]
14
Deepshikha Gautam, Negligence, Burnished Law Journal, Vol. 2 Issue 1 (2020).

11
Although statutory provisions give a broad platform, the RBI is the one that gives more
specific, binding and frequently revised guidelines that drive the daily banking operations.
The RBI is a regulator with regulatory authority under the Banking Regulation Act, 1949,
which provides it with the power to issue master circulars, directions, and supervisory
instructions, which banks have no option on whether to follow. These include key aspects like
Know Your Customer (KYC) standards, anti-money laundering protocols, the security of
digital payments, customer grievance redress, lockers safety standards and so on.

The adoption of the KYC Master Directions that mandates banks to verify the identity of
their customers, avert fraudulent accounts, and keep suitable records is one of the greatest
contributions of the RBI.15 Failure to adhere to such norms usually attracts negligence
conclusions at court. In the same way, the Cybersecurity Framework of Banks published in
2016 provides the requirements and guidelines on network security, fraud detection, incident
reporting, and customer protection regarding digital banking. These guidelines have a direct
impact on the responsibility of banks in ensuring that they protect the information of
consumers and avoid online frauds.

Furthermore, the RBI Banking Ombudsman Scheme provides a convenient platform to settle
dispute by the customers addressing accountability. In general, the duty of care imposed on
banks by RBI through the constant supervision and regulation is a major improvement of
customer protection in both the traditional and online banking setting.

7. Adequacy of Current Laws and RBI Guidelines

The current legal and regulatory system to regulate the duty of care in the Indian banking
system has a number of strengths. RBI instructions are comprehensive, constantly updated,
and applicable to all banks, providing equal standards of appropriate practices in such spheres
as KYC, fraud prevention, locks, and online payment. The laws such as the Banking
Regulation Act, the Negotiable Instruments Act and the Information Technology Act are all
encompassing in the aspects of banking activities such as the dispensation of cheques, use of
digital signature and general obligations of contracts. Indian courts also use consumer-
friendly interpretation whenever resolving disputes and tend to favour the protection of the
customers especially in disputes involving forged signatures, negligent cheque checks or

15
Diademy, Role and Functions of RBI in Maintaining Economic Stability, Diademy (last visited Nov. 22, 2025),
[Link]

12
failure to adhere to the KYC standards. This has developed a powerful body of jurisprudence
that explicitly spells out the obligations of banks.16

Nevertheless, in spite of such advantages, the framework has some serious shortcomings. The
fast pace of digitalisation has surpassed the current laws, with most of them being set to
operate using a conventional banking system and not as electronic transactions in real time.
No definite statutory framework to establish the liability of banks with regard to cyber fraud
has been established and this has led to lack of consistency in court verdicts. The growing
fintech environment is posing more risks by introducing new risks that deal with third-party
intermediaries, but there is still a legal grey area in terms of their liability. Moreover, other
banks do not have the well-developed cybersecurity system, making their customers more
susceptible to online fraud. The fact that there remains no national and universal criterion on
how to compensate victims of digital fraud further undermines the protection of the customer.
Thus, laws and guidelines are not completely relevant to the issues of modern, technology-
driven banking, and it leaves loopholes that should be addressed urgently.

8. Findings

The doctrinal examination indicates that the Indian courts view the relationship between the
banks and their customers as broad and dynamic where the bank is always subjected to a
broad duty of care regarding the nature of various transactions. The judiciary is very
committed to protecting the customers and it can be seen that the judicial ruling has found the
banks guilty of negligence in following KYC norms, locker management, cheque verification
and confidentiality breach among other issues. Courts tend to be consumer friendly because
they understand the power disparity and expertise between the banks and the customers.
Nevertheless, the research also concludes that digital banking has brought about novel types
of risk, including cyber fraud, unauthorised electronic transfer and data breach, which the
current laws fail to cover, since most of the regulations had been established in the context of
conventional banking. Even though the RBI guidelines are very helpful safeguards, their
performance relies much on their strict enforcement and frequent revision with the global
change in technology. Altogether, although the legal system remains solid in most aspects,
there are still major gaps that it is necessary to address with the advent of new digital issues,
which is why judicial development and regulations should be promoted further.

9. Suggestions and Recommendations

13
In order to enhance customer protection and maintain the duty of care towards customers in
the new online-based digital world, a number of reforms are required. To begin with, it is
obvious that the statutory change is necessary, which directly covers cyber fraud, online
transactions, and liability of digital banking as it is not fully covered by the current
legislation. Severer punishments of the failure to comply with KYC norms, cybersecurity
regulations, and instructions of the RBI would force banks to proceed with less risky
practices. The implementation of compulsory cyber insurance of all banks can also serve as a
way of ensuring that the customer is compensated as soon as possible in case of digital fraud
or data leakage. This should be accompanied by a clear and consistent policy on
reimbursement of online fraud victims so that customers are not faced with arbitrary and
unbalanced judgment. Also, the bank should provide regular training to the staff members to
enhance their capacity to report suspicious activity, avert fraud, and adhere to due checks of
verification. Enhancing customer awareness campaigns is also significant since most frauds
are committed because of the ignorance of users on the security practices. Moreover, regular
external audits of lockers and compliance procedures may assist in getting rid of laxity in
physical valuables management. Lastly, the increasing importance of fintech businesses and
third-party facilitators requires clear regulation to establish their responsibilities, liability, and
security levels so that the customers are ensured complete protection in all online platforms
and financial services.

10. Conclusion

The financial system depends on the relationship between the banker and the customer. The
legal interpretation of the duty of care owed by banks has been substantially influenced by
the Indian courts, which make banks accountable in the case of negligence over cheques and
identity check, locker control, confidentiality, and fraud control. Courts have set standards of
prudence that a reasonable banker should have through landmark judgments.

Nevertheless, the transition to the digital form of banking is fast and poses new challenges.
Although the current legislation and the RBI rules are a great source, they nonetheless lack
wholeness in meeting the current risks of digital banking. Stagnant statutory laws, ambiguity
in terms of liability and greater regulatory vigilance are in order.

This study finds that though the legal framework applicable to the duty of care of bankers in
India is sound, there is still need to continuously evolve the current framework to protect the
customers and instill confidence in the banking system to the masses.

14
11. Bibliography
1. Kuldeep Singh, Relationship Between Banker and Customer, 3 Int’l J. Trend Sci. Res.
& Dev. 1535 (2019), [Link]
2. Bharath Narayan, Banker as a Bailee, Int’l J. L. & Legal Research (IJLLR),
[Link]
3. [Link]
bailee-bailor-relationship/
4. Ashish Haldar, Bank Negligence and Customer Liability in India, 4 J. Banking Fin. &
Cyber L. 112.
5. Reserve Bank of India, Safe Deposit Locker / Safe Custody Article Facility – Revised
Instructions, Circular No. [Link]/40/09.07.005/2021-22 (Aug. 18, 2021),
[Link] (last visited Nov. 22, 2025).

15