Question: The bank verified the nominee's identity and granted access to a deceased customer's safe deposit locker. However, it handed over the locker contents without preparing the prescribed inventory. As per the RBI Master Circular on Customer Service in Banks, 2014, did the bank follow the required procedure for releasing the locker contents?
Answer: No, before releasing the locker contents, the bank should prepare an inventory in accordance with the prescribed procedure. Handling over the contents without preparing the inventory is not consistent with the RBI Master Circular.

Supporting evidence:
title: rbi.org.in/72MC010714CS.pdf
quote: Banks should prepare an inventory before returning articles left in safe custody / before permitting removal of the contents of a safe deposit locker
context: d undue hardship to legal heir(s) of the locker hirer(s). In case where the deceased locker hirer had not made any nomination or where the joint hirers had not given any mandate that the access may be given to one or more of the survivors by a clear survivorship clause, banks are advised to adopt a customer-friendly procedure drawn up in consultation with their legal advisers for giving access to legal heir(s) / legal representative of the deceased locker hirer. Similar procedure should be followed for the articles under safe custody of the bank.

21.3 Preparing Inventory

21.3.1 Banks should prepare an inventory before returning articles left in safe custody / before permitting removal of the contents of a safe deposit locker as advised in terms of Notification DBOD.NO.Leg.BC.38/C.233A-85 dated March 29, 1985. The inventory shall be in the appropriate Forms set out as enclosed to the above Notification or as near thereto as circumstances require. A copy of the above Notification is shown as Annex IV of this Circular.
21.3.2 Banks are not required to open sealed/closed packets left with them for safe custody or found in locker while releasing them to the nominee(s) and surviving locker hirers / depositor of safe custody article.
21.3.3. Further, in case the nominee(s) / survivor(s) / legal heir(s) wishes to continue with the locker, banks may enter into a fresh contract with nominee(s) / survivor(s) / legal heir(s) and also adhere to KYC norms in respect of the nominee(s) / legal heir(s).

21.4 Simplified operational systems / procedures

As per the direction of Reserve Bank, the Indian Banks' Association (IBA) has formulated a Model Operational Procedure (MOP) for settlement of claims of the deceased constituents , under various circumstances, consistent with the instructions contained in this circular, for adoption by the banks. The banks should, therefore, undertake a comprehensive review of their extant systems and procedures relating to settlement of claims of their deceased constituents (i.e., depositors / locker-hirers / depositors of safe-custody articles) with a view to evolving a simplified policy / procedures for the purpose, with the approval of their Board, taking into account the applicable statutory provisions, foregoing instructions as also the MOP formulated by the IBA.

Annex IV (See Paragraph 21.3)

March 29, 1985

In exercise of the powers conferred on the Reserve Bank of India by sub-section (3) of section 45ZC and sub-section (4) of s