Marshalling is meant to protect the junior creditor from the effect of choices of enforcement strategy by the senior creditor. This principle is employed to adjust the rights of various parties by ranking their priorities and determining the order in which the mortgaged property will be sold to satisfy the mortgage debt or debts.
There is no reason why the equitable rule of marshalling by a subsequent purchaser embodied in section 56 of the Transfer of Property Act should not be extended to sales other than private sales.
Accordingly though a decree-holder has a right to have all the properties mortgaged to him put up for sale, it is entirely in the discretion of the Court to direct in which order the properties should be sold, if by such direction, the Court can give relief to deserving parties without any prejudice to the interest of the decree-holder. ….. [Mahtabuddin vs. Nim Chandra Sachi (1952) 4 DLR 95]