SUPREME COURT
Promise To Arrange Funds In Case of Default Does Not Make Promoter A Guarantor: Supreme Court
Case Title: UV Asset Reconstruction Company Limited v. Electrosteel Castings Limited
Citation: 2026 LLBiz SC 3
Case Number: Civil Appeal No. 9701 of 2024
The Supreme Court of India has held that a promoter's promise to arrange funds to help a borrower meet financial covenants does not amount to a contract of guarantee under the Indian Contract Act and cannot be used to fasten insolvency liability on the promoter. A bench of Justice Sanjay Kumar and Justice Alok Aradhe said that for an obligation to qualify as a guarantee under Section 126 of the Act, there must be a clear and unambiguous promise by the surety to repay the borrower's debt if the borrower defaults.
Citation: Citation: 2026 LLBiz SC 13
Case Number: Civil Appeal No. 10261 of 2025
Case Title : Case Title: Elegna Co-op Housing And Commercial Society Ltd. v. Edelweiss Asset Reconstruction Company Limited & Anr.
The Supreme Court has held that housing societies lack the locus standi to intervene in the admission stage of insolvency proceedings, ruling that “right to initiate or participate in CIRP flows from the debt transaction and the statute, not from associative or representational interest.” While limiting third-party intervention, the court simultaneously directed that the Committee of Creditors (CoC) “shall mandatorily record cogent and specific reasons in writing” whenever it recommends liquidation or denies possession to homebuyers.
Supreme Court Says NCLT Could Not Have Decided Title Of Gloster Trademark In Fort Gloster Insolvency
Case Title : Gloster Limited vs Gloster Cables Limited & Ors.
Case Number : CIVIL APPEAL NO. 2996 OF 2024
CITATION : 2026 LLBiz SC 20
The Supreme Court on Thursday held that the National Company Law Tribunal could not have decided the ownership of the trademark “Gloster” while exercising powers under Section 60(5) of the Insolvency and Bankruptcy Code, as the dispute did not arise in relation to the insolvency resolution process. A bench of Justices J.B. Pardiwala and K.V. Viswanathan upheld the National Company Law Appellate Tribunal,decision setting aside the NCLT Kolkata's finding that the trademark belonged to the corporate debtor.
Supreme Court Asks NCLT To Re-Examine RP Appointment In Finefacilis Personal Guarantor Insolvency
Case Title : Samman Capital Limited v. Vasudevan Sathyamoorthy & Anr.
Case Number : Civil Appeal No. 555/2026
CITATION : 2026 LLBiz SC 29
The Supreme Court recently sent the issue of appointing a resolution professional in insolvency proceedings against a personal guarantor of Finefacilis Management Private Limited on a plea by Samman Capital back to the National Company Law Tribunal.
A bench of Justice J.B. Pardiwala and Justice K.V. Viswanathan set aside a Karnataka High Court order that had kept the NCLT's earlier decision in abeyance.
Supreme Court Refuses To Interfere With NCLAT Order Upholding CIRP Against Air Travel Enterprises
Case Title : E.M. Najeeb Ellias Mohammed vs Union Bank of India & Anr.
Case Number : CIVIL APPEAL NO. 4094 OF 2024
CITATION : 2026 LLBiz SC 25
The Supreme Court on Tuesday dismissed an appeal filed by E.M. Najeeb Ellias Mohammed, promoter of Kerala-based travel agency Air Travel Enterprises India Ltd., declining to interfere with an NCLT order admitting insolvency proceedings against the company as a corporate guarantor.
A bench of Justices Pamidighantam Sri Narasimha and Vijay Bishnoi held that no error of law or fact was committed by the National Company Law Tribunal.
Supreme Court Stays Probe Into Exclusive Capital, Allows NCLAT Proceedings To Continue
Case Title : Exclusive Capital Limited & Ors. vs Kanta Agarwala & ANR
Case Number : Civil Appeal No. 15207/2025
CITATION : 2026 LLBiz SC 27
The Supreme Court on Tuesday stayed the investigation ordered into the affairs of Exclusive Capital Limited, an NBFC, while issuing notice in an appeal filed by the company and its promoters.
It, however, clarified that the proceedings pending before the National Company Law Appellate Tribunal have not been stayed and would continue in accordance with law.
A bench of Justices Sanjay Kumar and K. Vinod Chandran directed that the investigation initiated pursuant to the order passed by the National Company Law Tribunal, New Delhi and affirmed by the National Company Law Appellate Tribunal on November 21, 2025, shall remain stayed until the next hearing.
HIGH COURT
Case Title: Reliance Defence & Engineering Ltd vs Afcons Infrastructure Ltd
Case Citation: 2026 LLBiz HC (BOM) 2
Case Number: IA (L) No. 9646 of 2024 in Arbitration Petition No. 1755 of 2015
The Bombay High Court has held that where an arbitral award passed against a company is under challenge, and the company later successfully comes out of insolvency, the award holder cannot retain money withdrawn from court deposits if the claim itself is wiped out under an approved resolution plan.
The court said such amounts must be returned, as the award itself no longer survives.
A single-judge bench of Justice Somasekhar Sundaresan, in an order dated December 17, 2025, allowed an interim application filed by Reliance Defence and Engineering Ltd. against Afcons Infrastructure Ltd.
High Courts Cannot Exercise Parallel Contempt Jurisdiction Over NCLT In IBC Cases: Bombay High Court
Case Title: S.G. Mittal Enterprises Pvt Ltd vs The Satara Sahakari Bank Ltd. and Ors
Case Citation: 2026 LLBiz HC (BOM) 7
Case Number: Contempt Petition No. 497 of 2025
The Bombay High Court on Monday held that contempt petitions alleging breach of orders passed by the National Company Law Tribunal in insolvency cases cannot be filed directly before the High Court.
A single-judge bench of Justice Milind N Jadhav said that once contempt powers are conferred on the NCLT by law, the High Court should not exercise parallel jurisdiction.
Case Title: Roseland Buildtech Private Limited v. Vihaan 43 Reality Private Limited & Ors.
Citation: 2026 LLBiz HC (DEL) 10
Case Number: C.S. (COMM.) 812/2025
The Delhi High Court has dismissed what it described as “luxury litigation” challenging a debt assignment, saying issues of fraud or the existence of debt must be decided by the insolvency tribunal, not a civil court.
A single-judge bench of Justice Purushaindra Kumar Kaurav rejected the suit at the threshold, holding that it was a “mala fide attempt” built on “clever drafting” to derail proceedings under the Insolvency and Bankruptcy Code. The court imposed costs of Rs 2 lakh, saying the case had wasted judicial time and “should never have been filed.”
Bank Can't Freeze Company's Accounts Solely Over ROC's 'Management Dispute' Tag: Calcutta High Court
Case Title: Ravindra Pratap and another vs Reserve Bank of India and others
Case Citation: 2026 LLBiz HC (CAL) 4
Case Number: MAT No. 989 of 2025, IA No: CAN 1 of 2025
The Calcutta High Court has held that a bank cannot freeze a company's accounts merely on the basis of a “management dispute” marking by the Registrar of Companies (ROC), particularly after such marking has been removed on the directions of the Ministry of Corporate Affairs (MCA).
Justices Sabyasachi Bhattacharyya and Supratim Bhattacharya made the observation on January 5 while hearing appeals filed by Ravindra Pratap Singh, director of August Agents Limited, challenging the freezing of the company's bank and demat accounts by Axis Bank in June 2021.
Delhi High Court Sets Aside Arbitration Against Bhushan Steel Following Tata Steel Takeover
Citation: 2026 LLBiz HC (DEL) 32
Case Number : W.P.(C) 10431/2020 & CM APPL. 33016/2020
Case Title : Tata Steel Limited v. Ministry of Corporate Affairs and Anr.
The Delhi High Court has set aside an arbitral tribunal order that allowed arbitration to continue against Tata Steel, formerly Bhushan Steel, even after its resolution plan under the Insolvency and Bankruptcy Code was approved. A single-judge bench of Justice Amit Sharma allowed Tata Steel's writ petition and quashed the tribunal's October 7, 2020 order. The court said that once a resolution plan is approved, it binds all creditors.
Case Title: Ahmednagar Forgings Ltd vs Dongare Ganesh D
Case Citation: 2026 LLBiz HC (BOM) 26
Case Number: Writ Petition No. 11862 of 2025
The Bombay High Court has held that once a resolution plan is approved by the National Company Law Tribunal (NCLT), labour courts and industrial tribunals cannot continue or entertain employee claims, including claims seeking reinstatement without back wages. Justice Arun R. Pedneker made the observation while allowing a batch of writ petitions filed by Ahmednagar Forgings Ltd, now Metalyst Forgings Ltd., challenging orders passed by the Labour Court and Industrial Tribunal at Aurangabad.
Case Title : MMS Steel and Power Private Limited v. Union of India and Ors
Case Number : WA No. 50 of 2026
CITATION : 2026 LLBiz HC (KER) 12
The Kerala High Court has refused to interfere with the National Company Law Tribunal's rejection of a resolution plan for an insolvent company, even though it had received 100% approval from the Committee of Creditors. A Division Bench of Chief Justice Soumen Sen and Justice Syam Kumar V.M. held that the NCLT was acting within its jurisdiction in examining the resolution plan and that writ jurisdiction could not be invoked merely because the tribunal disagreed with the Committee of Creditors.
Case Title : Arun Kumar Bagla v. SCJ Plastics Ltd.
Case Number : W.P. (CRL) 2165/2019 & CRL. M.A. 32848/2019
CITATION : 2026 LLBiz HC (DEL) 46
The Delhi High Court has said that a company's inability to pay its dues because of financial distress is a civil issue, not a criminal offense. A director cannot be prosecuted for cheating unless there is clear proof of personal fraud or personal gain. Justice Neena Bansal Krishna quashed cheating charges against a former managing director of Creative Wares Limited, a manufacturing company that later ran into financial trouble and was declared a sick industrial company by the BIFR.
NCLAT
Case Name: Ashok Mansukhlal Kapasi & Ors. v. Bhavi Shah (RP of Techno Forge Ltd.) & Ors.
Citation: 2026 LLBiz NCLAT 1
Case Number: Company Appeal (AT) (Ins) No.643 of 2024
The National Company Law Appellate Tribunal (NCLAT) at Delhi has reiterated an insolvency court cannot add new conditions to a resolution plan approved by lenders, and set aside a direction that required 5 percent equity of the corporate debtor to be reserved for public shareholders.
A bench of Judicial Member Justice N Seshasayee and Technical Member Arun Baroka said the clause had found its way into the order without any basis in the approved resolution plan.
Case Title: Airtech Airconditioning v. Parnika Commercial and Estate Private Limited
Citation: 2026 LLBiz NCLAT 2
Case Number: Company Appeal (AT) (Ins) No.502/2024
The National Company Law Appellate Tribunal (NCLAT) at Delhi on Wednesday set aside an order of the National Company Law Tribunal, Delhi, which had dismissed an insolvency application by invoking the Covid-19 bar under the Insolvency and Bankruptcy Code. The appellate tribunal held that the NCLT Delhi failed to consider invoices whose dates of default fell outside the Covid-19 excluded period.
A bench of Chairperson Justice Ashok Bhushan and Technical Member Barun Mitra said the approach adopted by the NCLT Delhi was flawed.
NCLAT Upholds Eviction Of Subsidiaries From Corporate Debtor's Properties During Liquidation
Case Title: Fivebro Water Services Pvt. Ltd. and Anr. Vs. Bijay Murmuria, Liquidator of Doshion Pvt. Ltd. and Ors.
Citation: 2026 LLBiz NCLAT 3
Case Number: Company Appeal (AT) (Insolvency) No. 1730 of 2025
The National Company Law Appellate Tribunal (NCLAT) at Delhi has upheld the NCLT Ahmedabad's order directing eviction of two subsidiaries from premises owned by a corporate debtor.
The court held that the NCLT can exercise jurisdiction under Section 60(5) of the Insolvency and Bankruptcy Code (which gives the insolvency court power to decide questions of law or fact arising out of or connected with insolvency or liquidation) to recover possession and rent during liquidation when the underlying leases are invalid.
Calling Guarantor 'Director' In SARFAESI Notice Doesn't Invalidate Invocation Of Guarantee: NCLAT
Case Title: Ujwal Gupta v Union Bank of India and Anr.
Citation: 2026 LLBiz NCLAT 4
Case Number: Company Appeal (AT) (Ins) No. 2001 of 2024
The National Company Law Appellate Tribunal (NCLAT) at New Delhi has recently ruled that merely describing a personal guarantor as a “Director” in a SARFAESI demand notice does not invalidate the invocation of the personal guarantee, as long as the notice clearly demands payment of the outstanding dues under the guarantee deed.
Case Title: Klassy Enterprises v. Competition Commission of India and Ors.
Citation: 2026 LLBiz NCLAT 5
Case Number: Competition Appeal (AT) No. 33 of 2022
The National Company Law Appellate Tribunal (NCLAT) at New Delhi has recently upheld a Rs 10 lakh penalty imposed by the Competition Commission of India on Klassy Enterprises, holding that paying the tender costs of rival bidders and submitting bids from the same IP address was enough to show bid rigging, even without a written cartel agreement.
A bench of Judicial Member Justice Mohd. Faiz Alam Khan and Technical Member Naresh Salecha dismissed Klassy Enterprises' appeal against the CCI's March 17, 2021 order.
NCLAT Limits Ansal Properties' Insolvency To Sushant Golf City and Rajasthan Projects
Case Title: Gagan Tandon & Ors. v. IL & FS Financial Services Ltd. & Ors.
Citation: 2026 LLBiz NCLAT 6
Case Number: Company Appeal (AT) (Ins.) Nos. 500 & 502 of 2025
The National Company Law Appellate Tribunal (NCLAT) at New Delhi refused to overturn the insolvency proceedings against Ansal Properties and Infrastructure Limited.
However, it restricted the process to Sushant Golf City in Lucknow and three Rajasthan projects: Ansal Royal Plaza, Orchid Plaza, and Tulip Plaza. The tribunal said extending the insolvency process to projects not linked to the loan securities was “uncalled for” and would disrupt unrelated real estate projects.
NCLAT Upholds ₹5,000 EPFO Allocation In CIRP of Metistech Fabrication Against ₹18.33 Lakh Claim
Case Title: Employees Provident Fund Organisation vs Subhlaxmi Investment Advisory Pvt Ltd and Anr
Citation: 2026 LLBiz NCLAT 7
Case Number: Company Appeal AT (Insolvency) No. 794 of 2025
The National Company Law Appellate Tribunal (NCLAT) at New Delhi has upheld a resolution plan that allocated only Rs 5,000 towards provident fund dues claimed by the Employees' Provident Fund Organisation. The tribunal held that the bulk of the EPFO's demand was unenforceable, as it was assessed after insolvency proceedings had already begun.
A bench of Judicial Member Justice N. Seshasayee and Technical Member Arun Baroka dismissed the EPFO's appeal against the resolution plan approved for Metistech Fabrication Private Limited, an Odisha based company. The tribunal said Section 14 of the Insolvency and Bankruptcy Code bars any fresh assessment or recovery action once a moratorium comes into force.
Case Title: In the Matter of: Consortium led by Syonira Invecast Pvt. Ltd v. Employees' Provident Fund Organisation & Anr.
Case Number: Company Appeal (AT) (Ins.) No. 2319 of 2024
Citation: 2026 LLBiz NCLAT 9
The National Company Law Appellate Tribunal (NCLAT) New Delhi has held that no assessment proceedings can be initiated or continued during the moratorium period under Section 14 of the Insolvency and Bankruptcy Code, 2016 (IBC) and no claim based on such assessment can be enforced against the Successful Resolution Applicant (SRA) after approval of the Resolution Plan. Section 14 of the IBC introduces a moratorium that halts legal actions against a corporate debtor once insolvency proceedings begin.
NCLAT Expunges Adverse Remarks Against IL&FS Companies In Wind World Insolvency
Case Title : Jogihali Wind Energy Private Limited v. Yogesh Mehra and Ors.
Case Number : Company Appeal (AT) (Ins) No. 1249 of 2022
CITATION : 2026 LLBiz NCLAT 21
The National Company Law Appellate Tribunal (NCLAT) at Delhi has expunged adverse remarks made by the NCLT Ahmedabad against three IL&FS group companies during the insolvency proceedings of Wind World (India) Limited. The appellate tribunal held that the observations were made without evidence and could not be allowed to remain.
A bench of Judicial Member Justice Mohd. Faiz Alam Khan and Technical Member Indevar Pandey said removing a creditor from the Committee of Creditors is not a minor issue. The tribunal stressed that such decisions require procedural fairness.
Credits To Bankrupt's Bank Account Don't Automatically Vest In Bankruptcy Estate: NCLAT
Case Title : Shubash Chandra Mishra, Personal Guarantor vs Sunil Kumar, Bankrupt Trustee &Anr.
Case Number : Comp. App. (AT) (Ins) No. 1300/2025
CITATION : 2026 LLBiz NCLAT 17
The National Company Law Appellate Tribunal (NCLAT) at New Delhi has ruled that money lying in the bank account of a bankrupt personal guarantor forms part of the bankruptcy estate and can be frozen by the Bankruptcy Trustee.
A bench of Chairperson Justice Ashok Bhushan and Technical Member Barun Mitra said that while all assets belonging to the bankrupt as of the bankruptcy commencement date vest in the trustee, the law treats assets acquired later differently.
Case Title : Rajiv Gupta v. Brijesh Singh Bhaduriya, Ertswhile RP of RCI Industries and Technologies Ltd and Ors.
Case Number : Comp. App.(AT) (Ins) No. 1859/2025
CITATION : 2026 LLBiz NCLAT 16
The National Company Law Appellate Tribunal (NCLAT) at New Delhi, has refused to interfere with the approval of a resolution plan for RCI Industries and Technologies Ltd., after the successful resolution applicant undertook not to claim any rights over two disputed properties and the plan was approved by the committee of creditors.
A bench comprising Chairperson Justice Ashok Bhushan and Technical Member Barun Mitra said, “Resolution Plan having been approved by the CoC and SRA having offered not to claim any right which has been accepted by Adjudicating Authority, we are of the view that at the instance of the Suspended Directors the said decision cannot be interfered with.”
NCLAT Issues Notice On REC's ₹37.48 Crore Insolvency Appeal Against Poena Power
Case Title : REC Limited v. Poena Power Development Limited
Case Number : Company Appeal (AT) (Insolvency) No. 92 of 2026
The National Company Law Appellate Tribunal (NCLAT) at New Delhi on Thursday issued notice on an appeal by Maharatna PSU REC Limited against an NCLT order that rejected its bid to start insolvency proceedings against Poena Power Development Limited, a subsidiary of RattanIndia Power Limited, over an alleged default of about Rs 37.48 crore. REC has challenged the NCLT's refusal to admit its Section 7 petition, which was dismissed on the ground that no legally enforceable debt had arisen. The tribunal had held that the claim stemmed from Redeemable Preference Shares (RPS) that had not become redeemable under the Companies Act, as the parent company lacked profits or funds raised through a fresh share issue.
NCLAT Sets Aside Aman Hospitality CIRP After Suspended Director Undertakes To Pay ₹119 Crore Dues
Case Title : Raj Singh Gehlot, Suspended Director of Aman Hospitality Private Limited v. Anup Kumar, IRP of Aman Hospitality Private Limited and Anr
Case Number : Comp. App. (AT) (Ins) No. 94 of 2026
CITATION : 2026 LLBiz NCLAT 15
The National Company Law Appellate Tribunal (NCLAT) on Thursday set aside insolvency proceedings against Aman Hospitality Private Limited after the suspended director undertook to pay Bank of India's dues within three days, overturning an NCLT Delhi order admitting the company into the Corporate Insolvency Resolution Process (CIRP).
A bench comprising Chairperson Justice Ashok Bhushan and Technical Member Barun Mitra allowed the appeal filed by suspended director Raj Singh Gehlot after taking on record his undertaking to settle the dues of the financial creditor, Bank of India.
NCLAT Lifts 'Impossible Condition' Of ₹40-Crore Security Imposed On Bankrupt Guarantor For US Travel
Case Title : Zankarsinh Kishorsinh Solanki v. Kanhaiyalal Salawat (Bankruptcy Trustee) & Ors. Case Number : Company Appeal (AT) (Insolvency) No. 2030 of 2025
CITATION : 2026 LLBiz NCLAT 14
The National Company Law Appellate Tribunal (NCLAT) has set aside a condition imposed by the NCLT Ahmedabad requiring a bankrupt personal guarantor to deposit Rs. 40 crore as security for travelling to the United States. The tribunal held that a person already declared bankrupt cannot be expected to arrange such funds.
A bench led by Chairperson Justice Ashok Bhushan and Technical Member Barun Mitra held that imposing an “impossible condition” amounts to denial of permission to travel.
Case Title : Rakesh Phull (RP of Shivam Continental Pvt. Ltd.) v. Punjab Small Industries & Export Corporation Ltd. & Anr.
Case Number : Comp. App. (AT) (Ins) No. 50 of 2026
CITATION : 2026 LLBiz NCLAT 13
The National Company Law Appellate Tribunal (NCLAT) at Delhi has refused to interfere with an order admitting a late claim in an insolvency case. The tribunal said the delay did not, by itself, warrant interference since the liability was already disclosed to bidders during the process.
A bench of Chairperson Justice Ashok Bhushan and Technical Member Barun Mitra noted that the Information Memorandum had flagged the dues. It had also cautioned resolution applicants to make their own enquiries.
“Sat Over Our Order”: NCLAT Seeks ISPT India IRP's Reply In Contempt Case
Case Title : National Company Law Appellate Tribunal Chennai Bench v. Anil Kumar Khicha Case Number : Contempt No. 1/2026 in Company Appeal (AT) (CH) (Ins) Nos. 531 & 532/2025 CITATION : 2026 LLBiz NCLAT 12
The National Company Law Appellate Tribunal (NCLAT) at Chennai has sought a reply from Anil Kumar Khicha, the Interim Resolution Professional (IRP) of ISPT India Pvt Ltd, in contempt proceedings after the tribunal earlier found that an email issued by him in the insolvency proceedings was contemptuous.
A bench comprising Judicial Member Justice Sharad Kumar Sharma and Technical Member Jatindranath Swain is dealing with the contempt proceedings arising from the insolvency proceedings of ISPT India Pvt Ltd.
NCLAT Upholds Adani Power's ₹4,000 Crore Resolution Plan For Vidarbha Industries
Case Title : Western Coalfields Ltd. v. Bimal Kumar Agarwal & Ors.
Case Number : Company Appeal (AT) (Insolvency) No. 1281 of 2025 with Company Appeal (AT) (Insolvency) No. 1317 of 2025
CITATION : 2026 LLBiz NCLAT 11
The National Company Law Appellate Tribunal (NCLAT) at Delhi has recently upheld Adani Power Limited's Rs 4,000 crore resolution plan for Vidarbha Industries Power Limited, rejecting challenges raised by Western Coalfields Limited, a fuel supplier and operational creditor, and an employee representative.
A bench of Chairperson Ashok Bhushan and Technical Member Barun Mitra held that changes made by Adani Power to the acquisition structure after the plan was approved by the committee of creditors were permitted under the plan itself.
NCLAT Quashes NCLT Condition Restricting Use of Rs 20 Crore In Carnival Films Resolution Plan
Case Title : Cine-Corp Filmdom Pvt. Ltd. v. Ashok Kumar Gulla (RP) & Anr.
Case Number : Company Appeal (AT) (Ins) No. 1614 of 2025
CITATION : 2026 LLBiz NCLAT 10
The National Company Law Appellate Tribunal (NCLAT) at New Delhi has set aside an NCLT Indore order that approved Carnival Films Private Limited's resolution plan but barred the use of nearly Rs. 20 crore lying in the company's bank account to pay creditors.
A bench of Judicial Member Justice Mohd. Faiz Alam Khan and Technical Member Arun Baroka said the NCLT had overstepped its jurisdiction. It noted that the NCLT had first recorded that the plan complied with Section 30(2) of the Insolvency and Bankruptcy Code and then imposed fresh conditions.
Related Party Supplies Not CIRP Costs Without CoC Approval: NCLAT In Amtek Auto Insolvency
Case Title : Lotus Auto Engineering Ltd. v. Dinkar T. Venkatasubramaniam & Ors.
Case Number : Company Appeal (AT) (Insolvency) No. 1356 & 1357 of 2023
CITATION : 2026 LLBiz NCLAT 28
The National Company Law Appellate Tribunal (NCLAT) at Delhi has dismissed a Rs 18.98 crore claim by Lotus Auto Engineering Limited, a group company of Amtek Auto Limited, holding that supplies made by a related party during the corporate insolvency resolution process cannot be treated as insolvency resolution process costs unless expressly approved by the Committee of Creditors.
A Principal Bench comprising Chairperson Justice Ashok Bhushan and Technical Member Barun Mitra held that permission granted by the CoC to undertake related party transactions cannot be equated with approval of expenses as insolvency resolution process costs entitled to priority payment.
NCLAT Dismisses Insolvency Appeal Against Larsen & Toubro Over Dues Claimed By Former Employee
Case Title : Manoj Seth v. Larsen and Toubro Ltd.
Case Number : Company Appeal (AT) (Ins) No. 2213 of 2024
CITATION : 2026 LLBiz NCLAT 27
The National Company Law Appellate Tribunal (NCLAT) at New Delhi has recently dismissed an insolvency appeal filed against Larsen & Toubro Ltd by a former senior employee over alleged unpaid salary and service benefits.
A Bench of Judicial Member Justice Mohd. Faiz Alam Khan and Technical Member Naresh Salecha upheld an order of the National Company Law Tribunal, Mumbai, which had rejected the employee's CIRP plea.
Intent Irrelevant Once Conditions Of Preferential Transaction Are Met: NCLAT Reiterates
Case Title : Rajesh Toshniwal and Anr. Versus Kamal Nayan Jain And Ors.
Case Number : Company Appeal (AT) (Ins) No. 1437 of 2023
CITATION : 2026 LLBiz NCLAT 26
The National Company Law Appellate Tribunal (NCLAT) at New Delhi has reiterated that a preferential transaction (Section 43 of the Insolvency and Bankruptcy Code) works on a statutory deeming fiction. Once the necessary ingredients are met, intent or motive does not matter. The burden shifts to the directors and beneficiaries to show that the transactions were in the ordinary course of business.
A bench of Judicial Member Justice Mohd. Faiz Alam Khan and Technical Member Naresh Salecha dismissed an appeal filed by the suspended directors of Toshniwal Enterprises Controls Limited.
NCLAT Upholds ₹6.56 Crore Liability on Paranjape Agro Promoter For Fraudulent Stock Write-Off
Case Title : Shri. Hrushikesh Balkrishna Paranjape v. Shri. Ajay Marathe & Anr.
Case Number : Company Appeal (AT) (Ins) No. 1994 of 2024
CITATION : 2026 LLBiz NCLAT 25
The National Company Law Appellate Tribunal (NCLAT) at New Delhi has recently held that the promoter-director of Paranjape Agro Products India Private Limited must personally repay Rs 6.56 crore to the company after finding that inventory shown in the books never existed and was written off to defraud creditors at a time when there was no reasonable prospect of avoiding insolvency.
A bench of Justice Mohd. Faiz Alam Khan and Technical Member Indevar Pandey upheld an order passed by the National Company Law Tribunal, Mumbai. The Appellate Tribunal agreed that the write-off was not a genuine business decision but a conscious act to erase inflated figures from the accounts.
NCLAT Remands Case After NCLT Failed To Record Finding On Homebuyers' Threshold in Insolvency Plea
Case Title : Mrudul Balwant Kulkarni Vs. Mrs. Kakumanu Lakshmi & Ors.
Case Number : Company Appeal (AT) (Insolvency) No.386 of 2023
CITATION : 2026 LLBiz NCLAT 24
The National Company Law Appellate Tribunal (NCLAT) at New Delhi has set aside an order of the NCLT Mumbai Bench admitting insolvency proceedings against a real estate developer, holding that the NCLT failed to record a clear finding on the statutory threshold required for homebuyers under the Insolvency and Bankruptcy Code. The matter has been remanded for a fresh determination limited to this issue.
Case Title : The Regional Provident Fund Commissioner-II v. M/s Harshavardhan Cotton and Synthetic Mills Private Limited and Anr
Case Number : Company Appeal (AT) (CH) (Ins.) No.455/2023
CITATION : 2026 LLBiz NCLAT 20
The National Company Law Appellate Tribunal (NCLAT) at Chennai has held that the provident fund dues of liquidation bound Harshavardhan Cotton and Synthetic Pvt. Ltd. could not have been treated as government dues during liquidation, even though the company had not maintained a separate provident fund account.
The tribunal said that, on the facts of the case, the amount claimed by EPFO had to be treated as a third-party asset and paid before the liquidation waterfall was applied.
No Right To Insist On OTS After Default: NCLAT Upholds Insolvency Against Karanja Terminal
Case Title : Brig. Vikram Singh, Suspended Director of Karanja Terminal & Logistics Pvt. Ltd. Vs. Karanja Terminal & Logistics Pvt. Ltd., Through Vijay P. Lulla, IRP & Ors.
Case Number : Company Appeal (AT) (Insolvency) Nos. 1928-1931 of 2025
CITATION : 2026 LLBiz NCLAT 23
The National Company Law Appellate Tribunal (NCLAT) at New Delhi has upheld the admission of insolvency proceedings against Karanja Terminal & Logistics Pvt. Ltd., holding that repeated and unsuccessful one-time settlement proposals do not prevent action under Section 7 of the Insolvency and Bankruptcy Code once debt and default are established.
A bench headed by Chairperson Justice Ashok Bhushan, with Technical Member Barun Mitra, said the settlement proposals relied upon by the corporate debtor never went beyond the stage of proposals, as they did not receive unanimous approval of the consortium lenders.
Case Title : The Committee of Creditors of Nirmal Lifestyle (Kalyan) Pvt. Ltd. v. Shailendra Ajmera, Resolution Professional & Anr.
Case Number : Company Appeal (AT) (Insolvency) No.1521 of 2025
CITATION : 2026 LLBiz NCLAT 22
The National Company Law Appellate Tribunal (NCLAT) at New Delhi has held that a belated expression of interest in an insolvency process cannot be accepted unless a provisional list of bidders is first published and objections are invited. The court reiterated that it is a mandatory requirement under the Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) Regulations, 2016.
NCLT
Common Resolution Professional For Group Companies Not Barred Under IBC: NCLT Mumbai
Case Title: Jubin Kishore Thakkar v. Ashutosh Agarwala & Anr
Citation: 2026 LLBiz NCLT (MUM) 1
Case Number: I.A. No. 59/2025 IN C.P. NO. 881(IB)/MB/2023
The National Company Law Tribunal (NCLT) at Mumbai recently held that the Insolvency and Bankruptcy Code, 2016 does not prohibit the appointment of a single resolution professional for companies belonging to the same corporate group. According to the tribunal, such an appointment does not by itself create a conflict of interest.
A coram of Judicial Member Lakshmi Gurung and Technical Member Hariharan Neelakanta Iyer, while dismissing a plea seeking removal of a common resolution professional, refused to remove Ashutosh Agarwala as the resolution professional of KLT Automotive and Tubular Products Limited.
Case Title: JVS Comatsco Industries Pvt Ltd vs Pankaj Kumar Tibrewal, Committee of Creditors of Incab Industries Ltd
Case Citation: 2026 LLBiz NCLT (KOL) 2
Case Number: I.A. (IB) No. 685/KB/2025 in CP (IB) No. 1684/KB/2018
The National Company Law Tribunal (NCLT) at Kolkata , has recently held that a bidder who joined the first round of the insolvency process but stayed out of the second, restored round cannot later challenge a resolution plan approved by lenders.
A coram of Judicial Member Labh Singh and Technical Member Rekha Kantilal Shah, in an order dated December 3, observed that participation in the restored CIRP process is essential to challenge the same.
Liquidator Cannot Claim Fee On SARFAESI Realisations Outside Liquidation Estate: NCLT Ahmedabad
Case Title: Ramesh Kumar Totla v. State Bank of India Stressed Assets Management Branch
Citation: 2026 LLBiz NCLT (AHM) 3
Case Number: IA No. 1002 (AHM) 2025 in C.P.(IB) 74 (AHM) 2024
The National Company Law Tribunal (NCLT) at Ahmedabad recently held that when a secured creditor enforces its security interest under the SARFAESI Act without involving the liquidator, the amount realised does not form part of the liquidation estate. The liquidator therefore count in that sale to compute the liquidator's fee.
A coram of Judicial Member Shammi Khan and Technical Member Sanjeev Sharma, while dealing with an application filed by liquidator Ramesh Kumar Totla against State Bank of India in the liquidation of Raghuvanshi Cotton Ginning and Pressing Private Limited
Refunds Under Vivad Se Vishwas Scheme Cannot Be Enforced Under Insolvency Jurisdiction: NCLT Chennai
Case Title: R Venkatakrishnan (RP) M/s Star Trace Pvt Ltd v. Hindustan Copper Ltd
Citation: 2026 LLBiz NCLT (CHE) 4
Case Number: IA/IB/2365/CHE/2024 in IBA/304/2020
The National Company Law Tribunal (NCLT) at Chennai has held that refunds claimed under the Vivad Se Vishwas–I Scheme, a government COVID-19 relief measure that allows MSMEs to seek return of most performance guarantees forfeited during the pandemic, cannot be enforced through insolvency proceedings under Section 60(5) of the Insolvency and Bankruptcy Code.
Insolvency Threshold For Transferred Cases Depends On Filing Date, Not Transfer Date: NCLT Bengaluru
Case Title: Lapp India Private Limited v. Schenker India Private Limited
Citation: 2026 LLBiz NCLT (BEN) 5
Case Number: IA (IBC) 635 /2025 in TP (IBC) 05/ 2024 in CP 21/2014
The National Company Law Tribunal (NCLT) at Bengaluru has recently held that winding-up and insolvency cases transferred from High Courts continue to be governed by the monetary threshold that applied when they were first filed, and not by the higher limits introduced later.
The tribunal made this ruling in a dispute between logistics firm Schenker India Private Limited and Lapp India Private Limited.
NCLT Bengaluru Dismisses Insolvency Plea Over Rs 428 Crore Claim Against Atria Group Firm
Case Title: Piramal Capital & Housing Finance Ltd. & Anr. v. Atria Brindavan Power Pvt. Ltd.
Citation: 2026 LLBiz NCLT (BEN) 6
Case Number: CP (IB) No. 185/BB/2024
The National Company Law Tribunal (NCLT) at Bengaluru has dismissed an insolvency plea seeking to recover over Rs. 428 crore from Atria Group's renewable energy arm, Atria Brindavan Power.
The plea was filed by Piramal Capital and Housing Finance Limited and Omkara Assets Reconstruction Private Limited. It said the case was about recovering money, not resolving insolvency.
A coram of Judicial Member Sunil Kumar Aggarwal and Technical Member Radhakrishna Sreepada found that the insolvency process was being used as pressure tactic against a solvent company.
NCLT Jaipur Imposes Rs 5 Lakh Cost On Jaipur Company for Malicious Voluntary Insolvency Plea
Case Title: M.D Suitings Pvt Ltd v. State Bank of India and Ors
Citation: 2026 LLBiz NCLT (JAI) 10
Case Number: IA No. 251/JPR/2023 in CP No. (IB)- 11/10/JPR/2023
The National Company Law Tribunal (NCLT) at Jaipur has imposed a cost of Rs. 5 lakh on a Jaipur-based company after holding that it had misused the insolvency process to block recovery action by State Bank of India.
The tribunal dismissed the insolvency petition filed by M.D. Suitings Pvt. Ltd. for its own insolvency under Section 10 of the Insolvency and Bankruptcy Code, finding it to be fraudulent and malicious.
NCLT Mumbai Approves ₹16.10 Crore Klassic Wheels' Resolution Plan for Indian Refrigerator Company
Case Title: Silveroak Home Appliances Pvt Ltd vs Indian Refrigerator Company Ltd
Citation: 2026 LLBiz NCLT (MUM) 8
Case Number: IA (PLAN)/37/2025 in CP (IB)/252(MB)2024
The National Company Law Tribunal (NCLT) at Mumbai has approved a Rs. 16.10 crore resolution plan submitted by Klassic Wheels Ltd for the revival of debt-laden Indian Refrigerator Company Ltd, bringing the resolution process to an end.
A coram of Judicial Member Nilesh Sharma and Technical Member Charanjeet Singh Gulati, in an order dated December 19, 2025, held that the plan complied with all mandatory requirements under the Insolvency and Bankruptcy Code and therefore deserved approval.
IBC Cannot Waive Statutory Requirements Under Other Laws: NCLT Mumbai
Case Title: AmitKumar Rishi Kumar Bhabhda & Ors vs Amit Chandrasehkhar Poddar & Ors
Case Citation: 2026 LLBiz NCLT (MUM) 7
Case Number: IA (I.B.C) No. 5599/MB/2023 in CP (IB) No. 1620/MB/2017
The National Company Law Tribunal at Mumbai has recently held that the Insolvency and Bankruptcy Code does not wipe out the need for statutory approvals or licenses required under other laws, even after a resolution plan is approved or a company is sold as a going concern during liquidation.
The tribunal made it clear that the insolvency framework is meant to streamline timelines, not to bypass regulatory compliance.
Case Title: Central Bank of India v. A Dominic Savio
Case Number: CP(IB)/217(CHE)/2021
Citation: 2026 LLBiz NCLT (CHE) 18
The National Company Law Tribunal (NCLT) at Chennai recently held that insolvency proceedings under the Insolvency and Bankruptcy Code, 2016, can be initiated against a personal guarantor even if he is a foreign citizen and does not own any assets in India.
The tribunal said nationality and absence of property in India do not prevent the Code from applying.
A coram of Judicial Member Sanjiv Jain and Technical Member Venkataraman Subramaniam rejected the objection to the maintainability of the proceedings against the personal guarantor of Oceanic Edibles International Ltd, which is already under liquidation.
NCLT Ahmedabad Orders Recovery of ₹2 Lakh Costs From Personal Guarantor As Arrears of Land Revenue
Case Title: Yash Thakarshibhai Gajera and Anr v. Bank of India
Citation: 2026 LLBiz NCLT (AHM) 20
Case Number: CP(IB)/322(AHM)2025
The National Company Law Tribunal (NCLT) at Ahmedabad has directed that costs of Rs 2 lakh imposed earlier on a personal guarantor be recovered as arrears of land revenue, after finding that he had repeatedly ignored its order and failed to pay the amount.
A coram of Judicial Member Justice Shammi Khan and Technical Member Sanjeev Sharma noted that the personal guarantor had shown continued and wilful non-compliance.
Fraud Has No Look-Back Period, Directors Cannot Use Lapse Of Time As Shield : NCLT Kochi
Case Title: K.J. Vinod vs Mukeshbhavan Mukesh Karthikeyan & Ors
Case Citation: 2026 LLBiz NCLT (KOC) 22
Case Number: IA(IBC)/303/KOB/2024 in CP(IBC)/57/KOB/2022
The National Company Law Tribunal (NCLT) at Kochi has held that allegations of fraudulent and wrongful trading are not restricted by any fixed look-back period, and directors cannot avoid personal liability merely by arguing that the conduct took place long ago. It therefore directed the suspended directors of a Kochi-based insolvent company to jointly contribute Rs 11.95 crore to the company's assets.
Case Title: Dhyaneshwar Shankar Unde Proprietor of Swadarshan Dairy Products v. Shukla Dairy Private Limited
Citation: 2026 LLBiz NCLT (AHM)
Case Number: CP (IB) No.239/9/AHM/2020
The National Company Law Tribunal (NCLT) at Ahmedabad has dismissed an insolvency plea against Shukla Dairy Private Limited, holding that once parties settle and the case is closed, an operational creditor cannot reopen insolvency proceedings without clear bank records showing a fresh default.
A coram of Judicial Member Shammi Khan and Technical Member Sanjeev Sharma said bare allegations of non-payment are not enough, especially when the corporate debtor places specific proof of payment on record.
Case Title: Prem Agarwal v. Anil Kumar Satyanarayan Agarwal
Citation: 2026 LLBiz NCLT (AHM) 23
Case Number: I.A. No.1389/NCLT(AHM)/2025 in CP(IB) No.211/9(AHM)2025
The National Company Law Tribunal (NCLT) at Ahmedabad has recently held that a settlement between an operational creditor and a suspended director cannot be used to withdraw a company from insolvency once the Committee of Creditors is in place.
Dismissing a withdrawal plea in the insolvency of Vimla Fuels & Metals Limited, the tribunal said such a private arrangement cannot override the claims of financial creditors exceeding Rs 61 crore.
Avoidance Provisions Under Insolvency Code Are Restorative, Not Punitive: NCLT Kochi
Case Title: CA Sreenivasan PR vs Astern Realtors Pvt Ltd & Ors
Case Citation: 2026 LLBiz NCLT (KOC) 26
Case Number: IA(IBC)/239/KOB/2025 IN CP(IBC)/12/KOB/2024
The National Company Law Tribunal at Kochi has clarified that the avoidance provisions under the Insolvency and Bankruptcy Code are meant to undo the preferential effect of certain transactions and restore the corporate debtor's estate, not to impose punitive liability on the beneficiary.
Judicial Member Vinay Goel made the observation while partly allowing an avoidance application filed by the Resolution Professional of Astern Properties and Developers Pvt Ltd under Sections 43 and 44 of the Code.
NCLT Mumbai Approves Sagacious Capital's Rs 110 Crore Plan To Revive Reliance Innoventures
Case Title: JC Flowers Asset Reconstruction Pvt Ltd vs Reliance Innoventures Pvt Ltd
Case Citation: 2026 LLBiz NCLT (MUM) 27
Case Number: I.A. 62/2024 in C.P. NO. 1154(IB)/MB/2020
The National Company Law Tribunal (NCLT) at Mumbai has approved a Rs. 110.10 crore resolution plan submitted by Sagacious Capital Pvt Ltd for the revival of debt-ridden Reliance Innoventures Pvt Ltd. The tribunal held that once a plan satisfies the requirements of the Insolvency and Bankruptcy Code, the tribunal cannot interfere with the commercial decisions of lenders.
A bench comprising Judicial Member Mohan Prasad Tiwari and Technical Member Charanjeet Singh Gulati observed that the resolution plan complied with statutory requirements under Section 30(2) of the IBC and the relevant CIRP Regulations.
Case Title: Ramachander Rao Bikumalla and Splendid Metal Products Ltd
Case Citation: 2026 LLBiz NCLT (HYD) 13
Case Number: IA (IBC) No. 124 of 2022 in CP (IB) No. 504/10/HDB/2018
The National Company Law Tribunal (NCLT) at Hyderabad has held that when a corporate debtor has received full consideration and acted upon a slump sale transaction, he cannot later reclaim the property on the ground that the agreement was unregistered, as such conduct is barred by the doctrine of estoppel.
A coram of Judicial Member Rajeev Bhardwaj and Technical Member Sanjay Puri dismissed a set of applications filed by the liquidator of Handum Industries Ltd, which has been under liquidation since June 11, 2021.
The approval came on January 6, 2026, following resolutions passed by the boards of the companies on February 4 and February 12, 2025. Under the scheme, the appointed date for the first leg of the demerger has been fixed as October 1, 2024, while the second leg will take effect from January 1, 2025.
CIRP Claims Cannot Rely On 12-Year Limitation Period For Enforcing Mortgage Rights: NCLT Mumbai
Case Title: Omkara Asset Reconstruction Private Limited v. Gigeo Construction Private Limited and ors.
Citation: 2026 LLBiz NCLT (MUM) 30
Case Number: CP (IB) 1180 (MB)2022
The National Company Law Tribunal (NCLT) at Mumbai has recently ruled that secured creditors cannot rely on the 12-year limitation period for enforcing mortgage rights when filing claims in a corporate insolvency resolution process. For insolvency claims, the Tribunal said, the applicable limitation period is three years.
The decision was delivered by a coram of Judicial Member Sushil Mahadeorao Kochey and Technical Member Prabhat Kumar.
Case Title: Abhay Narhar Kadam vs Vakati Balasubramanyam Reddy
Citation: 2026 LLBiz NCLT (MUM) 29
Case Number: IA (IBC) NO. 3078 OF 2025 IN CP (IB) NO. 144/MB/2021
The National Company Law Tribunal (NCLT) at Mumbai has dismissed a challenge by a suspended director seeking disclosure of valuation reports and other Corporate Insolvency Resolution Process (CIRP) documents. The court held that valuation reports are confidential and cannot be shared with persons who are themselves potential or competing resolution applicants.
Fraud Claims On Insolvency Admission Must Be Raised In Appeal, Not In Later NCLT Pleas: NCLT Kolkata
Case Title: Pramila Bajoria & Ors vs Eastern Udyog Finance Ltd & Ors
Case Citation: 2026 LLBiz NCLT (KOL) 31
Case Number: IA (IB) NO. 1583/KB/2024 IN C.P (IB) NO. 309/KB/2022
The National Company Law Tribunal (NCLT) at Kolkata has recently held that allegations of fraud or collusion in the admission of insolvency proceedings cannot be raised months later through a fresh application and must be pursued through the appellate route provided under the law.
A bench of Judicial Member Bidisha Banerjee and Technical Member Siddharth Mishra said former promoters cannot use Section 65 of the Insolvency Code to challenge an admission order they never appealed.
Case Title: Sanctuary Apartment Owner's Association vs K. Parameswaran Nair and Ors
Citation: 2026 LLBiz NCLT (KOC) 35
Case Number: IA (IBC)/265/KOB/2024 in CP (IBC)/05/KOB/2021
The National Company Law Tribunal (NCLT) at Kochi has ruled that apartments and project land covered only by sale or construction agreements cannot be treated as “assets held in trust” for homebuyers when a builder enters insolvency. The tribunal said such properties continue to belong to the builder during the Corporate Insolvency Resolution Process until sale deeds are executed and registered.
A coram of Judicial Member Vinay Goel said the Insolvency and Bankruptcy Code does not permit property to be taken out of the insolvency process merely because buyers have entered into agreements or paid money.
MoU Between Debtor And Creditor Is Only Acknowledgment, Not Proof Of Debt: NCLT Mumbai
Case Title: Mulraj Mody vs Westin Habitats Pvt Ltd
Citation: 2026 LLBiz NCLT (MUM) 33
Case Number: RCP (IB)/16(MB)2024
The National Company Law Tribunal (NCLT) at Mumbai has said that a Memorandum of Understanding (MoU) can, at best, show an acknowledgment of debt, but it cannot, by itself, prove that a financial debt exists or that there has been a default. The tribunal said documents showing the original loan and actual disbursal of money are necessary to trigger insolvency proceedings.
A coram of Judicial Member Nilesh Sharma and Technical Member Sameer Kakar dismissed a petition filed by Mulraj Mody against Westin Habitats Pvt Ltd, which sought initiation of the corporate insolvency resolution process (CIRP) based on MoUs and settlement documents.
NCLT Mumbai Approves Supreme Capinfra's Rs. 96 Crore Plan To Revive C & M Farming
Case Title: Orion Resolution & Turnaround Pvt Ltd vs Committee of Creditors of C and M Farming Ltd
Case Citation: 2026 LLBiz NCLT (MUM) 38
Case Number: IA (PLAN)/66/2025 in CP (IB)/1031(MB)2021
The National Company Law Tribunal (NCLT) at Mumbai has approved a Rs 96.81 crore resolution plan for the revival of C and M Farming Ltd, a poultry business. The tribunal held that once a resolution plan meets the requirements of the Insolvency and Bankruptcy Code, it cannot interfere with the commercial decisions of the Committee of Creditors. A coram comprising Judicial Member Mohan Prasad Tiwari and Technical Member Charanjeet Singh Gulati passed the order on January 9. The bench found the plan to be fully compliant with Section 30(2) of the Code and the applicable regulations.
Delay In Seeking Revised Valuation Of Asset Not Enough To Term It Sham: NCLT Mumbai
Case Title: Subhash Ganpatrao Buty vs Pankaj Bhattad
Case Citation: 2026 LLBiz NCLT (MUM) 37
Case Number: IA NO. 5019 of 2025 in CP No. (IB) 1180 (MB) 2022
The National Company Law Tribunal (NCLT) at Mumbai has held that a revised valuation obtained after discovery of additional restrictions on a property cannot be dismissed as a sham merely because there was a delay in seeking such revision. It said valuation is a technical exercise and must be assessed in light of the facts available to the valuer at the relevant time.
Disputed Property Cannot Be Excluded From Information Memorandum After CoC Approval: NCLT Mumbai
Case Title: Jayesh Krushnakant Parekh vs Orion Resolution & Turnaround Pvt Ltd
Case Citation: 2026 LLBiz NCLT (MUM) 36
Case Number: IA (IBC) No. 2137 of 2025 in CP (IB) No. 1031/MB/2021
The National Company Law Tribunal (NCLT) at Mumbai has held that once a resolution plan is approved by the Committee of Creditors (CoC) and awaits confirmation, permitting amendments to the Information Memorandum would unsettle the resolution process.
Case Title: Techntrans Construction India Pvt Ltd vs SBI
Case Citation: 2026 LLBiz NCLT (HYD) 40
Case Number: IA (IBC)/1616/2025 in CP (IB)/74/94/HDB/2024
The National Company Law Tribunal (NCLT) at Hyderabad has recently ordered the bankruptcy of Pasam Laxmi Srinivas Reddy, the personal guarantor of Techtrans Constructions India Private Limited, an infrastructure firm. The tribunal said there was no repayment plan on record and no way forward for resolution. The order was passed by Judicial Member Rajeev Bhardwaj and Technical Member Sanjay Puri. Setting out the reason in clear terms, the bench said, “Admittedly, the repayment plan has not been submitted by the personal guarantor, and since there is no resolution plan for resolving the insolvency, we accept the prayer of the applicant and admit this petition to declare the personal guarantor bankrupt.”
NCLT Hyderabad Orders Dissolution of Srianagha Sky Scrapers After Voluntary Liquidation Under IBC
Case Title: Srinagha Sky Scrapers Pvt Ltd and Registrar of Companies, Telangana
Case Citation: 2026 LLBiz NCLT (HYD) 41
Case Number: CP (IB)/110/59/HDB/2025
The National Company Law Tribunal (NCLT) has recently ordered the dissolution of Srianagha Sky Scrapers Private Limited, a Hyderabad-based infrastructure company, after recording the successful completion of its voluntary liquidation under the Insolvency and Bankruptcy Code, 2016. The order was passed by the Hyderabad Bench on January 8, 2026. A coram comprising Judicial Member Rajeev Bhardwaj and Technical Member Sanjay Puri, said it was satisfied that the process was carried out strictly as required under the law.
Requests For Time Or Settlement Does Not Amount To Pre-Existing Dispute Under IBC: NCLT Mumbai
Case Title: Incred Value Plus Pvt Ltd vs Atum Capital Pvt Ltd
Case Citation: 2026 LLBiz NCLT (MUM) 44
Case Number: CP (IB)/894/MB/2025
The National Company Law Tribunal at Mumbai has held that requests for time, settlement, or proposals for alternative arrangements does not amount to a dispute under the Insolvency and Bankruptcy Code and therefore do not negate an admitted liability. A coram of Judicial Member Nilesh Sharma and Technical Member Sameer Kakar, in an order dated January 12, said such communications far from raising a genuine dispute, often reinforce acknowledgement of debt.
Recall Order Cannot Cure Failure To File Claims During Liquidation: NCLT Ahmedabad
Case Title: Pratham Realty Developers v. Nirav Tarkas and Ors.
Citation: 2026 LLBiz NCLT (AHM) 43
Case Number: IA/377(AHM)2021 in C.P. (I.B.) No. 03 (AHM) 2017
Holding that reopening a matter for fresh hearing cannot make up for a failure to follow mandatory legal procedures, the National Company Law Tribunal at Ahmedabad has dismissed an insolvency-related application filed by Pratham Reality Developers Private Limited against Stratus Foods Pvt. Ltd The application sought payment of licence fees, occupation charges and other dues during the liquidation process.
Case Title: Sagar Sharma & Anr. vs Committee of Creditors & Anr.
Case Citation: 2026 LLBiz NCLT (MUM) 45
Case Number: I.A. NO. 4764 OF 2025 IN C.P. NO. (IB) 1241 (MB) OF 2022
The National Company Law Tribunal (NCLT) at Mumbai has clarified that a member of the Committee of Creditors (CoC) is not barred from voting on a resolution plan merely because its related persons have an interest in the consortium of a resolution applicant. It said insolvency law does not prescribe any such disqualification on the ground of conflict of interest. A coram of Judicial Member Sushil Mahadeorao Kochey and Technical Member Prabhat Kumar dismissed an application filed by the suspended promoters of Hotel Horizon Pvt Ltd challenging the approval of a resolution plan during its corporate insolvency resolution process.
Interest-Free Loans, Write-Offs Not Fraudulent Per Se Without Intent: NCLT Mumbai
Case Title: Dinkar T. Venkatasubramanian vs Arun Kumar Maiti and Ors.
Case Citation: 2026 LLBiz NCLT (MUM) 46
Case Number: IA 2839 of 2024 In CP IB 1555 of 2017
The Mumbai bench of the National Company Law Tribunal (NCLT) has held that accounting irregularities or regulatory violations, including the grant of interest-free advances, do not by themselves amount to fraudulent trading. It clarified that fraudulent trading can be established only when there is clear, cogent evidence showing an intent to defraud creditors, assessed in the context of the company's business model.
Financial Creditor Cannot Avoid Liquidation Costs After Settling Dues Through OTS: NCLT Bengaluru
Case Title: Ravindranath Narayana Rao v. Jammu & Kashmir Bank Ltd
Case Number: I.A. No. 397 of 2025 in C.P. (IB) No. 286/BB/2019
Citation: 2026 LLBiz NCLT (BEN) 49
The National Company Law Tribunal (NCLT) at Bengaluru has held that a financial creditor that participated in the liquidation process and secured its dues through a one-time settlement cannot later avoid paying its share of liquidation costs for the ime it had taken part in it. A coram of Judicial Member Sunil Kumar Aggarwal and Technical Member Radhakrishna Sreepada directed Jammu & Kashmir Bank Ltd to bear its proportionate share of liquidation expenses in the liquidation of Alpine Wineries Pvt Ltd.
NCLT Admits Insolvency Plea Against Aman Hospitality Over ₹119 Crore Default
Case Title: Bank of India v. Aman Hospitality Private Limited
Citation: 2026 LLBiz NCLT(DEL) 51
Case Number: CP (IB) – 276(ND)/2025
The National Company Law Tribunal (NCLT) at Delhi has admitted Bank of India's insolvency plea against Delhi- based Aman Hospitality Private Limited over a default of about Rs 119 crore, excluding its equity, following a plea by Bank of India. A coram comprising President Justice Ramalingam Sudhakar and Technical Member Ravindra Chaturvedi passed the order on January 12, 2026. The dispute arises from loans sanctioned for Aman's five-star hotel project in Shahdara, Delhi. Between 2010 and 2011, a banking consortium extended facilities aggregating over Rs 160 crore. Bank of India was one of the lenders.
NCLT Mumbai Rejects GNIDA Plea To Recall 2017 Shirdi Industries Resolution Plan
Case Title: Greater Noida Industrial Development Authority vs Devendra Padamchand Jain
Citation: 2026 LLBiz NCLT (MUM) 48
Case Number: IA 3803 of 2024 In CP IB 839 of 2017
The National Company Law Tribunal (NCLT) at Mumbai has dismissed an application filed by the Greater Noida Industrial Development Authority (GNIDA) seeking recall of a 2017 order approving Rakesh Agarwal's resolution plan for Shirdi Industries Ltd. It held that GNIDA was informed of the insolvency process and failed to file its claim despite specific notice. A coram of Judicial Member Sushil Mahadeorao Kochey and Technical Member Prabhat Kumar held that Noida authority could not allege violation of principles of natural justice after it chose not to participate in the insolvency process. It ruled that the approval of the resolution plan was neither ex parte nor illegal.
NCLT Admits 'Sip On' Maker Manpasand Beverages To Insolvency Over ₹25 Crore Dues
Case Title: Tetra-Pak India Private Limited v. Manpasand Beverages Limited
Case Number: CP(IB) 812 of 2019
Citation: 2026 LLBiz NCLT (AHM) 56
The National Company Law Tribunal (NCLT) at Ahmedabad has admitted Manpasand Beverages Limited, the maker of the popular mango drink Sip On, into corporate insolvency proceedings on a plea by iits packaging partner Tetra Pak India Private Limited. The plea was admitted over unpaid dues of more than Rs 25 crore for the supply of packaging material, machinery and related services provided by Tetra Pak to Manpasand under multiple agreements.
Participating Interest In Oil Block Qualifies as 'Property' Under IBC: NCLT Mumbai
Case Title: Pan India Consultants Pvt Ltd vs Amit Chandrakant Shah & Anr.
Case Citation: 2026 LLBiz NCLT (MUM) 47
Case Number: IA 4589 of 2025 In CP IB 973 of 2020
The National Company Law Tribunal (NCLT) at Mumbai has ruled that rights under Production Sharing Contracts are “property” under the Insolvency and Bankruptcy Code. As a result, a company's participating interest in an onshore oil block must be treated as an asset during insolvency and cannot be excluded from resolution. A coram of Judicial Member Sushil Mahadeorao Kochey and Technical Member Prabhat Kumar dismissed an application filed by Pan India Consultants Pvt Ltd seeking exclusion of the Participating Interest (PI) held by Frost International Ltd in an onshore oil block in the Cambay Basin from the insolvency process.
Case Title: Krithika Subramanian v. Indian Bank
Case Number: CP(IB)/257(CHE)/2025
The National Company Law Tribunal (NCLT) at Chennai has recently observed that merely filing an insolvency petition after the initiation of proceedings under the SARFAESI Act does not, by itself, indicate an attempt to delay or obstruct recovery proceedings. A coram of Judicial Member Sanjiv Jain and Technical Member Venkataraman Subramanian was hearing a petition filed by a personal guarantor seeking initiation of personal insolvency resolution proceedings under Section 94 of the Insolvency and Bankruptcy Code, 2016.
Full Payment Of Admitted Claim In Guarantor's CIRP Bars Creditor's Recovery From Principal Borrower
Case Title: Omkara Asset Reconstruction Private Limited v. Amit Pareek
Case Number: IA(IBC)/137/GB/2024 IA(IBC)(Plan)/1/GB/2024 and IA(IBC)/50/GB/2025 in CP(IB)/9/GB/2019
Citation: 2026 LLBiz NCLT (GUA) 59
The NCLT Guwahati has recently held that full settlement of an admitted claim under a resolution plan in the corporate guarantor's CIRP discharges the debt, extinguishing the creditor's rights against both the borrower and the guarantor. A coram of Judicial Member Rammurti Kushawaha and Technical Member Yogendra Kumar Singh was dealing with applications arising out of the Corporate Insolvency Resolution Process of National Plywood Industries Limited.
Case Title: Santanu T Ray vs Sunil Kumar Trivedi & Ors.
Case Citation: 2026 LLBiz NCLT (MUM) 58
Case Number: IA 4619/2023
The National Company Law Tribunal (NCLT) at Mumbai has suggested that the Insolvency and Bankruptcy Board of India issue an advisory to insolvency professionals and financial creditors on reducing their dependence on information supplied by suspended management and on actively using third-party sources to reconstruct company records. A coram of Judicial Member Sushil Mahadeorao Kochey and Technical Member Prabhat Kumar made the suggestion while dealing with an application filed by the resolution professional of Neo Corp International Ltd, who alleged fraudulent transactions during the period before the company entered insolvency.
Mere Pendency Of Appeal Does Not Stall Bankruptcy Proceedings: NCLT Kochi
Case Title: Tata Capital Limited v. Bobby Abraham
Case Number: IA(IBC) /488 /KOB/2025 in CP (IBC)/ 42//KOB/2024 & IA(IBC) /490 / KOB/2025 in CP(IBC)/ 44/ KOB/ 2024 & IA(IBC)/ 491/KOB/2025 in CP(IBC)/ 51/KOB/2024 & IA(IBC)/ 489/ KOB/2025 in CP(IBC)/ 52/KOB/ 2024 & CP(IBC)/ 492/KOB/ 2025 in CP(IBC)/ 53/ KOB/2024
Citation: 2026 LLBiz NCLT (KOC) 60
The National Company Law Tribunal (NCLT), Kochi Bench, on 14 January held that the mere pendency of an appeal does not operate as a stay on proceedings under the Insolvency and Bankruptcy Code, 2016 (IBC), in the absence of a specific interim order from the appellate forum. A Bench presided over by Judicial Member Vinay Goel was dealing with a batch of applications filed by Tata Capital Limited seeking initiation of bankruptcy proceedings against five personal guarantors of Simtel Trading Corporation Private Limited.
NCLT Mumbai Sets Aside Reclassification of PNB from Secured To Unsecured Creditor In Arshiya CIRP
Case Title: Punjab National Bank vs Pankaj Mahajan
Case Citation: 2026 LLBiz NCLT (MUM) 64
Case Number: IA 2913 of 2025 IN CP (IB)/ 3143 (MB) 2019
The National Company Law Tribunal (NCLT) at Mumbai has recently set aside the resolution professional's (RP) unilateral reclassification of Punjab National Bank (PNB) from a secured to an unsecured creditor in the corporate insolvency resolution process of Arshiya Ltd. A bench of Technical Member Prabhat Kumar and Judicial Member Sushil Mahadeorao Kochey held that once PNB's claim had been admitted, the resolution professional had no authority to alter its classification. It held that any such change could only be made pursuant to directions of the adjudicating authority
Case Title: Consortium of Ashdan Properties Pvt Ltd & Ors
Case Citation: 2026 LLBiz NCLT (MUM) 55
Case Number: I.A. NO. 3032 OF 2025 IN C.P. NO. (IB) 1241 (MB) OF 2022
The National Company Law Tribunal (NCLT) at Mumbai has held that Prospective Resolution Applicants (PRAs) are required to exercise due care and diligence while submitting resolution plans. It said the applicants cannot later fault the insolvency process merely because they discovered additional information from the public domain. A coram comprising Judicial Member Sushil Mahadeorao Kochey and Technical Member Prabhat Kumar dismissed an application filed by the consortium of Ashdan Properties Pvt. Ltd., a PRA in the corporate insolvency resolution process (CIRP) of Hotel Horizon Private Ltd.
Party Taking Over Contract Cannot Deny Liability By Claiming No Privity: NCLT Mumbai
Case Title: Baij Nath Ram Nath (India) Pvt Ltd vs Trivenimudrai Project Ltd
Case Citation: 2026 LLBiz NCLT (MUM) 54
Case Number: CP (IB) No. 265/MB/2025
The National Company Law Tribunal (NCLT) at Mumbai has held that where a party steps into the shoes of the original contracting entity and expressly assumes contractual obligations, it cannot subsequently evade liability by pleading absence of privity of contract. It said that a party that has solemnly entered into a written arrangement acknowledging specific obligations cannot be permitted to approbate and reprobate by later denying those very obligations.
Negative Cash Balances, Salary Mismatches Alone Don't Prove Fraud: NCLT Ahmedabad
CITATION : 2026 LLBiz NCLT (AHM) 65
Case Number : I.A. No. 828/NCLT(AHM)/2020 in CP(IB) No. 17/7(AHM)2019
Case Title : Bhavi Shreyans Shah (Liquidator) v. Champat Sanghvi and Ors.
The National Company Law Tribunal (NCLT) at Ahmedabad has held that accounting lapses such as a small negative cash balance, salary mismatches, and routing of funds through non-consortium banks do not, by themselves, amount to fraudulent or wrongful trading under the Insolvency and Bankruptcy Code. A coram of Judicial Member Shammi Khan and Technical Member Sanjeev Kumar Sharma said that every irregularity in accounts cannot be treated as fraud.
Financial Creditor Cannot Avoid Liquidation Costs After Settling Dues Through OTS: NCLT Bengaluru
Case Title: Ravindranath Narayana Rao v. Jammu & Kashmir Bank Ltd
Case Number: I.A. No. 397 of 2025 in C.P. (IB) No. 286/BB/2019
Citation: 2026 LLBiz NCLT (BEN) 49
The National Company Law Tribunal (NCLT) at Bengaluru has held that a financial creditor that participated in the liquidation process and secured its dues through a one-time settlement cannot later avoid paying its share of liquidation costs for the ime it had taken part in it. A coram of Judicial Member Sunil Kumar Aggarwal and Technical Member Radhakrishna Sreepada directed Jammu & Kashmir Bank Ltd to bear its proportionate share of liquidation expenses in the liquidation of Alpine Wineries Pvt Ltd.
Defying CIRP Orders 'Not In Public Interest', Amounts To Civil Contempt: NCLT Mumbai
Case Title: Pravin R. Navandar vs Sagar Sharma & Anr.
Case Citation: 2026 LLBiz NCLT (MUM) 57
Case Number: Cont.A. (IBC)/33/MB/2025 IN CP(IB) No. 1241 of 2022
The National Company Law Tribunal (NCLT) at Mumbai has held that deliberate disobedience of its directions during a corporate insolvency resolution process (CIRP), even on the ground that the quantification of a financial creditor's claim is pending in appeal, is against public interest and amounts to civil contempt. Allowing a contempt application filed by the resolution professional (RP) of Hotel Horizon Private Limited against its suspended directors, coram of Judicial Member Sushil Mahadeorao Kochey and Technical Member Prabhat Kumar said that their conduct “meets the ingredients of section 2(b) of the Contempt of Courts Act, 1971.”
NCLT Delhi Admits Rana Kapoor Family Company Bliss House Into Insolvency Over ₹922-Crore Default
Case Title : J.C. Flower Asset Reconstruction Pvt. Ltd. v. Bliss House Private Limited
Case Number : CP (IB) No. 585/ND/2025
CITATION : 2026 LLBiz NCLT (DEL) 87
The National Company Law Tribunal (NCLT) at Delhi has admitted Bliss House Private Limited, a real estate firm promoted by the family of Yes Bank founder Rana Kapoor, into insolvency over alleged defaults of about Rs 922.46 crore. The tribunal held that an arbitral award can extend the limitation period for initiating insolvency proceedings even if the award is under challenge.
A bench of Judicial Member Ashok Kumar Bhardwaj and Technical Member Reena Sinha Puri admitted a CIRP plea filed by J.C. Flowers Asset Reconstruction Private Limited.
NCLT Upholds ₹1 Notional Admission Of MCD's Rs 6,000-Crore Claim Against MEP Infrastructure
Case Title : Municipal Corporation of Delhi vs Ravindra Kumar Goyal
Case Number : IA (I.B.C) No. 5963/MB/2024 IN CP (IB) No. 973/MB/2023
CITATION : 2026 LLBiz NCLT (MUM) 83
The National Company Law Tribunal (NCLT) at Mumbai has upheld the treatment of a Rs. 6,000-plus crore claim filed by the Municipal Corporation of Delhi in the insolvency process of MEP Infrastructure Developers Ltd. The tribunal refused to interfere with the notional admission of the claim and its classification as unsecured.
A bench of Judicial Member K.R. Saji Kumar and Technical Member Anil Raj Chellan held that the admission of MCD's claim at a notional value of Rs. 1 did not warrant interference. The remaining amount of Rs. 6,073.35 crore continued to be reflected as a contingent claim in the insolvency process.
Case Title : Sarga Hotel Pvt Ltd and Anr vs West Bengal State Electricity Distribution Company Ltd Case Number : I.A.(IB) No. 2481/KB/2024 in C.P. (IB) No. 302/KB/2021
CITATION : 2026 LLBiz NCLT (KOL) 85
The National Company Law Tribunal (NCLT) at Kolkata has held that electricity dues linked to a corporate debtor's lessor cannot be imposed on a successful resolution applicant or used to deny a fresh electricity connection for revival of the corporate debtor.
A bench of Judicial Member Labh Singh and Technical Member Rekha Kantilal Shah observed that once a resolution plan is approved, the corporate debtor is entitled to a clean slate, with only those pre-CIRP claims extinguished that were duly admitted during the insolvency process.
NCLT Mumbai Approves Rs 345.6 Crore Hirani Ventures Plan For E-Commerce Magnum
Case Title : J.C. Flowers Assets Reconstruction Pvt Ltd vs E-Commerce Magnum Solution Ltd
Case Number : IA (I.B.C) (Plan) No. 115/MB/2025 in CP (IB) No. 364/MB/2021
CITATION : 2026 LLBiz NCLT (MUM) 84
The National Company Law Tribunal (NCLT) at Mumbai has approved a Rs. 345.60 crore resolution plan submitted by Hirani Ventures Pvt Ltd for E-Commerce Magnum Solution Ltd. The tribunal said it cannot interfere with the commercial decisions of lenders once a resolution plan complies with the Insolvency and Bankruptcy Code.
A bench of Judicial Member Ashish Kalia and Technical Member Sanjiv Dutt held that the plan met all requirements under Section 30(2) of the Code.
NCLT Mumbai Approves ₹467 Crore JSW Infrastructure Plan For NCR Rail Revival
Case Title : Edelweiss Asset Reconstruction Company Ltd vs NCR Rail Infrastructure Ltd
Case Number : IA (I.B.C) (Plan) No.87/MB/2025 in CP (IB) No.1079/MB/2022
CITATION : 2026 LLBiz NCLT (MUM) 82
The National Company Law Tribunal (NCLT) at Mumbai has approved a Rs 467.47 crore resolution plan submitted by JSW Infrastructure Limited for the revival of NCR Rail Infrastructure Limited, which operates a private freight terminal at Khurja in Uttar Pradesh. The plan was approved after receiving 100 percent voting approval from the Committee of Creditors.
A coram of Judicial Member Ashish Kalia and Technical Member Sanjiv Dutt, in an order pronounced on January 22, 2026, held, “In view of the aforesaid discussions and the settled legal position, we are of the considered view that the Plan meets the requirements of Section 30(2) of the Code and Regulations 37, 38, 38(1A), and 39(4) of the CIRP Regulations. The Plan is not in contravention of any of the provisions of Section 29A of the Code, as undertaken by the SRA, and is in accordance with the law.”
Case Title : India Bank v. Nipun Verma
Case Number : CP (IB) No. 571/MB/2024
CITATION : 2026 LLBiz NCLT (MUM) 81
The National Company Law Tribunal at Mumbai has recently admitted Indian Bank's insolvency petition against Nipun Verma, a personal guarantor for Frost International Limited, after rejecting his objection that the claim was time-barred.
A bench of Judicial Member Sushil Mahadeorao Kochey and Technical Member Prabhat Kumar held that the petition was filed within limitation. The tribunal said limitation was saved both by the Supreme Court's Covid extension orders and by a subsequent acknowledgement of debt in the borrower's audited accounts.
IBC Moratorium Not Automatic, Applies Only After Express Order: NCLT Mumbai
Case Title : Patanjali Foods Ltd (Formerly Known As Ruchi Soya Industries Limited) vs ICICI Bank Ltd
Case Number : IA (I.B.C)/1983 (MB) 2025 & IA (I.B.C)/2915 (MB) 2025 IN C.P. (IB)/1371(MB)2017 CITATION : 2026 LLBiz NCLT (MUM) 80
The National Company Law Tribunal (NCLT) at Mumbai recently held that a moratorium under the Insolvency and Bankruptcy Code does not commence automatically on the insolvency commencement date and can take effect only when it is expressly declared by the adjudicating authority. On this basis, the tribunal dismissed applications filed by Patanjali Foods Ltd., formerly Ruchi Soya Industries Ltd., which came under Patanjali following approval of a resolution plan, seeking retrospective application of the moratorium against ICICI Bank and reversal of debits amounting to Rs 65.83 crore from the corporate debtor's bank accounts.
Approved Resolution Plan Cannot Be Modified Even If Plan Allows It: NCLT Mumbai
Case Title : Shanti G.D. Ispat and Power Pvt Ltd vs Dhiren Shantilal Shah & Ors
Case Number : I.A. (IB) No. 5533 of 2024 IN C.P. (IB) No. 271/MB/2021
CITATION : 2026 LLBiz NCLT (MUM) 71
The National Company Law Tribunal at Mumbai has held that a resolution plan approved under the Insolvency and Bankruptcy Code cannot be modified or amended after approval by the adjudicating authority, even if the plan itself contains a clause permitting such modification. The tribunal said that once a plan receives statutory approval under Section 31 of the Code, it attains finality and becomes binding on all stakeholders, including the successful resolution applicant, which cannot be reopened on contractual grounds.
OCDs Not Converted Into Equity By Notice Alone: NCLT Admits CIRP Against Arcturus Developers
Case Title : Beacon Trusteeship Limited v. Arcturus Developers Pvt. Ltd
Case Number : CP (IB) – 209/ND/2025
CITATION : 2026 LLBiz NCLT (DEL) 76
The National Company Law Tribunal (NCLT) at Delhi has admitted insolvency proceedings against Arcturus Developers Private Limited for a default of Rs 1,258.73 crore, holding that a mere conversion notice does not legally convert debt into equity unless mandatory statutory steps are completed.
A bench of Judicial Member Ashok Kumar Bhardwaj and Technical Member Reena Sinha Puri held that Optionally Convertible Debentures (OCDs) continue to retain the character of “financial debt” in the absence of actual allotment of equity shares.
Case Title : Joshi v. Shikharchand Jain, Liquidator of Dhanlaxmi Solvex Pvt. Ltd.
Case Number : TP No. 246 of 2019
CITATION : 2026 LLBiz NCLT (MUM) 75
The National Company Law Tribunal, Indore Bench, has held that a labor court award by itself cannot give priority to old workmen's dues in liquidation under the Insolvency and Bankruptcy Code. The tribunal said that priority for workmen's dues is limited to amounts arising in the twenty-four months preceding the liquidation commencement date as per waterfall mechanism
A coram of Judicial Member Brajendra Mani Tripathi and Technical Member Man Mohan Gupta said a prior labour adjudication cannot alter the IBC waterfall under Section 53.
Case Title : Unity Small Finance Bank Limited v. Bafna Motors Private Limited.
Case Number : 110. IA/80/2026 C.P. (IB)/344(MB)2025
CITATION : 2026 LLBiz NCLT (MUM) 73
The National Company Law Tribunal (NCLT), Mumbai Bench, has recently clarified that a resolution professional's duties under the Insolvency and Bankruptcy Code are limited to taking custody and control of a corporate debtor's assets and do not extend to improving their value.
A bench of Judicial Member Mohan Prasad Tiwari and Technical Member Charanjeet Singh Gulati noted that the corporate insolvency resolution process (CIRP) against Bafna Motors began on October 14, 2025.
NCLT Ahmedabad Admits Another Blu-Smart Entity To Insolvency Over Rs 142 Cr Default
Case Title : Catalyst Trusteeship Limited v. Blu-Smart Charge Private Limited
Case Number : CP(IB) No. 483/7/AHM/2025
CITATION : 2026 LLBiz NCLT (AHM) 66
The National Company Law Tribunal (NCLT) at Ahmedabad has admitted Blu-Smart Charge Private Limited into the Corporate Insolvency Resolution Process after a default of Rs 142.95 crore on debenture payments.
A bench of Judicial Member Shammi Khan and Technical Member Sanjeev Sharma admitted a petition filed by Catalyst Trusteeship Limited under Section 7 of the Insolvency and Bankruptcy Code. The bench said the material on record clearly showed the existence of a financial debt and a default.
NCLT Mumbai Dismisses Workmen's Belated Wage Claims Against IL&FS, Cites Moratorium
Case Title : S.A. Azad, Authorised Representative of Workmen vs Infrastructure Leasing and Financial Services Ltd.
Case Number : IA (COMPANIES.ACT)/120 (MB) 2025 IN CP/3638 (MB) 2018
CITATION : 2026 LLBiz NCLT (MUM) 79
The National Company Law Tribunal (NCLT) at Mumbai has dismissed an application filed by S.A. Azad, the authorised representative of 31 workmen, seeking admission of wage claims against Infrastructure Leasing and Financial Services Ltd. (IL&FS). The tribunal dismissed the application on the grounds that the claims were barred by the 2018 moratorium and filed beyond the extended timelines, while also noting that the workmen were not directly employees of IL&FS.
NCLT Amaravati Cautions Against Presuming Corporate Actions Are Always Properly Approved
Case Title : Global Enterprise and Another vs Suvarnabhoomi Infra Developers Pvt Ltd
Case Number : CP (IB)/57/7/AMR/2024
CITATION : 2026 LLBiz NCLT (AMR) 72
The National Company Law Tribunal (NCLT) at Amaravati, while admitting a real estate company into insolvency, held that the absence of a board resolution authorising the borrowing of funds and execution of promissory notes on behalf of the company did not, in the facts of the case, defeat the existence of a financial debt.
At the same time, it cautioned against a mechanical reliance on the doctrine of indoor management to validate such transactions.
NCLT Ahmedabad Admits Takshashila Heights Into CIRP After Supreme Court Order
Case Title : Edelweiss Asset Reconstruction Company Limited v. Takshashila Heights Private Limited
Case Number : CP (IB) No. 104 of 2024
CITATION : 2026 LLBiz NCLT (AHM) 89
The National Company Law Tribunal (NCLT) Ahmedabad Bench has recently admitted real estate developer Takshashila Heights Private Limited into insolvency after the Supreme Court dismissed the company's challenge to its financial creditor, leaving no discretion under the Insolvency and Bankruptcy Code.
A coram of Judicial Member Chitra Hankare and Technical Member Dr. V. G. Venkata Chalapathy allowed the Section 7 CIRP plea filed by Edelweiss Asset Reconstruction Company Limited.
Case Title : Athena India Oppurtunities v. Mr. Bhuvan Madan, RP
Case Number : IA (IBC) NO. 1614 OF 2025 IN CP (IB) NO. 1245/MB/2021
CITATION : 2026 LLBiz NCLT(MUM) 90
The National Company Law Tribunal (NCLT) at Mumbai has directed the Committee of Creditors to reconsider Athena India's modified resolution plan in the insolvency of Arshiya Northern FTWZ Limited, a logistics and warehousing company operating a Free Trade and Warehousing Zone.
The tribunal held that denying an opportunity to consider value-enhancing modifications was arbitrary and contrary to the objective of value maximization under the insolvency framework
Pledged Shares Already With Creditor Need Not Be Returned During CIRP: NCLT Mumbai
Case Title : Maitreya Doshi vs Kanak Doshi & Ors
Case Number : IA (IBC) NO. 3117 OF 2023
CITATION : 2026 LLBiz NCLT (MUM) 74
The National Company Law Tribunal (NCLT) at Mumbai has held that, in the facts of the case, pledged shares that were already lying in the custody of a secured creditor before the start of the corporate insolvency resolution process did not need to be transferred back to the corporate debtor's demat account during insolvency.
A bench of Judicial Member Nilesh Sharma and Technical Member Charanjeet Singh Gulati held that, in this case, the Insolvency and Bankruptcy Code allows only preservation of the existing asset position during CIRP and does not permit enhancement of the corporate debtor's assets by taking away a secured creditor's security.
Case Title : Sanctury Apartments Owner Association v. K Parmeshwaran Nair and Ors.
Case Number : IA(IBC)/265/KOB/2024 CP (IBC)/05/KOB/2021
CITATION : 2026 LLBiz NCLT (KOC)92
The National Company Law Tribunal (NCLT) at Kochi has recently held that a homebuyers' association cannot challenge the insolvency framework after submitting a resolution plan under it while hearing the insolvency of Samson and Sons Builders and Developers Private Limited.
The order was passed by Judicial Member Vinay Goel. The tribunal said a party cannot accept the decisions of the Committee of Creditors and later question the same decisions after stepping into the role of a resolution applicant.
NCLT Mumbai Admits Smaaash Leisure To Insolvency Over Rs. 32 Crore Unpaid Debt
Case Title : J.C. Flowers Asset Reconstruction Pvt Ltd Vs Smaaash Leisure Ltd
Case Number : C.P. (IB)/698(MB)2025
CITATION : 2026 LLBiz NCLT (MUM) 95
The National Company Law Tribunal (NCLT) at Mumbai has admitted an insolvency petition filed by J.C. Flower Asset Reconstruction Ltd against Smaash Leisure Ltd, a popular Indian gaming and entertainment company engaged in sports simulation technology and virtual reality games, for default of Rs. 32.19 crores.
Smaaash Entertainment is the operational entity that runs and markets the “Smaaash” brand, while Smaaash Leisure Ltd is a group company. Smaaash, which had undergone insolvency proceedings, was revived after a resolution plan submitted by Nazara Technologies Pvt Ltd was approved on May 7, 2025.
NCLT Approves ₹919-Crore Oberoi Realty-Led Plan To Revive Hotel Horizon
Case Title : Pravin R. Navandar vs Consortium Of Oberoi Realty Limited, Shree Aman Developers Private Limited And JM Financial Properties And Holdings Limited
Case Number : IA (IBC) (PLAN) No. 110 of 2025 in CP (IB) 1241 of 2022
CITATION : 2026 LLBiz NCLT (MUM) 96
The National Company Law Tribunal (NCLT) at Mumbai has approved a Rs 919-crore resolution plan submitted by a consortium comprising Oberoi Realty Ltd, Shree Aman Developers Pvt Ltd and JM Financial Properties and Holdings Ltd for the revival of debt-laden Hotel Horizon Pvt Ltd.
A bench comprising Judicial Member Sushil Mahadeorao Kochey and Technical Member Prabhat Kumar noted that the resolution plan complied with all mandatory provisions of the Insolvency and Bankruptcy Code and applicable regulations.
RP Cannot Refuse Creditor Substitution Merely Because CoC Has Approved Resolution Plan: NCLT Kolkata
Case Title : AUTHUM INVESTMENT & INFRASTRUCTURE LIMITED vs SWAPNIL JAIN Case Number : I.A (IB) NO. 1800/KB/2024 IN C.P(IB) NO. 1699/KB/2018
CITATION : 2026 LLBiz NCLT (KOL) 94
The National Company Law Tribunal at Kolkata has held that a resolution professional cannot refuse substitution of a financial creditor merely because the corporate insolvency resolution process has progressed substantially or because a resolution plan has been approved by the Committee of Creditors (CoC) but is yet to receive approval of the adjudicating authority.
A coram of Judicial Member Bidisha Banerjee and Technical Member Siddharth Mishra observed that under the insolvency law, a valid assignee of financial debt steps into the shoes of the assignor and acquires all statutory rights including participation and voting in the CoC.
NCLT Directs 33 Schools Using 'Presidium' Brand to Deposit Trademark Revenue Into CIRP Account
Case Title : AAA Insolvency Professionals v. Praveen Kumar and Ors.
Case Number : IA No. 652/ND/2024 in CP (IB) No. 559 of 2021
CITATION : 2026 LLBiz NCLT (DEL) 97
The National Company Law Tribunal (NCLT) at New Delhi has directed 33 schools operating under the “Presidium” name to render accounts of amounts received and profits generated from use of the trademark and deposit the same into the Corporate Insolvency Resolution Process (CIRP) account of Presidium Educational Institution Private Limited.
A coram of Judicial Member Manni Sankariah Shanmuga Sundaram and Technical Member Atul Chaturvedi held that the continued use of the trademark without a valid licence amounts to infringement of the corporate debtor's statutory and proprietary rights.
Case Title : Axis Bank Ltd Vs Sevenhills Healthcare Pvt Ltd
Case Number : IA (IBC) (PLAN)/1/2026 IN TCP (IB)/32/7/AMR/2019
CITATION : 2026 LLBiz NCLT (AMR) 98
The National Company Law Tribunal (NCLT) at Amravati has approved a Rs. 884.82 crores resolution plan submitted by Capri Global Holdings Pvt Ltd for revival of Sevenhills Healthcare Pvt Ltd. The tribunal reiterated that once a resolution plan satisfies the statutory requirements under the Insolvency and Bankruptcy Code, judicial interference with the commercial wisdom of lenders is impermissible.
Judicial Member Kishore Vemulapalli noted that the plan met all requirements under the Code and the applicable CIRP Regulations, including provisions relating to payment of insolvency resolution costs, treatment of operational creditors and protection of dissenting financial creditors.
NCLT Chennai Directs Re-Verification of SBI Claim In Apollo Polyvinyl Insolvency
Case Title : Canara Bank v. Ashok Sheshadri and Anr
Case Number : IA (IBC) 2022/ (CHE)/ 2023 In CP (IB) 226/ (CHE)/ 2022
CITATION : 2026 LLBiz NCLT (CHE) 101
The National Company Law Tribunal (NCLT) at Chennai has recently held that a resolution professional cannot mechanically admit a lender's claim during insolvency proceedings when it distorts voting power in the committee of creditors. The tribunal ordered a fresh verification of the claim admitted in favour of the State Bank of India in the insolvency of Apollo Polyvinyl Private Limited.
A coram of Judicial Member Jyoti Kumar Tripathi and Technical Member Ravichandran Ramasamy said higher diligence was required in such cases. This was especially so where the claim of a consortium member exceeded that of the lead bank.
OTHER STORIES
IBBI Simplifies Liquidation Reporting With Four New Online Forms
Circular No: IBBI/LIQ/91/2026
Date: January 05, 2026
The Insolvency and Bankruptcy Board of India (IBBI) has introduced a simplified framework for reporting liquidation updates to the board. To facilitate the same, the Board has introduced four new online forms that track a company's liquidation from start to finish.
In a circular issued on Monday (Januray 5) , the Board said the revised system applies from January 1, 2026, and replaces the existing liquidation reporting framework.
Directors No Longer Need Annual KYC, MCA Moves Filing To Three-Year Cycle
Notification: Gazette Notification No. G.S.R 943 (E) dated 31st December, 2025
The Ministry of Corporate Affairs has relaxed compliance requirements for company directors by moving Director Know Your Customer filings from an annual exercise to once every three years.
The change was notified on December 31, 2025, through the Companies (Appointment and Qualification of Directors) Amendment Rules, 2025, and will take effect from March 31, 2026.
As per the new rules, individual directors who hold a Director Identification Number as on March 31 of a financial year will no longer have to complete KYC every year. Instead, they will be required to file a KYC intimation once after every three consecutive financial years.
IBBI Appellate Authority Raps Valuer Over 'Nil' Valuation of Assets Worth ₹960 Crore In Uniply CIRP
The Appellate Authority of the Insolvency and Bankruptcy Board of India (IBBI) has set aside a lenient three-month suspension imposed on a registered valuer for assigning nil value to financial assets worth over Rs 960 crore, including cash, during the insolvency process of Uniply Industries Limited.
In an order dated January 7, 2026, IBBI Chairperson Ravi Mital said the penalty was far too mild and sent the matter back to the Disciplinary Committee for fresh consideration. The valuer, R. Vaidyanathan, has also been barred from taking any new assignments until the show cause notice is finally decided.