A 2-judge bench of the Supreme Court — *J.S. Verma, J.* and *K. Jayachandra Reddy, J.* — held in March 1992 that a bank has a general lien on fixed deposit receipts in its possession under *Section 171* of the *Indian Contract Act 1872*, supplemented by the contractual right to set-off, and that an FDR deposited under a covering letter authorising retention 'so long as any amount is due' cannot be attached by a third-party decree-holder ahead of the bank's lien. The judgment distinguished the general lien from the particular lien under *Section 170* and is the foundational authority for the banker-customer set-off architecture in India.