LiveLawBiz IBC Weekly Digest: June 15 - June 20, 2026

Update: 2026-06-22 08:48 GMT

SUPREME COURT 

Supreme Court Issues Notice On Challenge To Gujarat HC Ruling Against Transfer Of Essar Steel Cases To Mumbai NCLT 

Case Title :  UNION OF INDIA AND ANR. Versus ARCELORMITTAL NIPPON STEEL INDIA LIMITED FORMERLY KNOWN AS ESSAR STEEL INDIA 

Case Number :  Diary No. 24062-2026

The Supreme Court on Monday issued notice on the Union government's challenge to a Gujarat High Court judgment concerning the transfer of Essar Steel-related proceedings from the National Company Law Tribunal (NCLT) Ahmedabad to Mumbai. A bench of Chief Justice Surya Kant and Justice V. Mohana tagged the matter with connected cases raising similar issues and posted it for hearing on July 29.

Voizzit Moves SC Against HC Order Striking US Bankruptcy Trustee From Suit Claiming Interest In Byju'S US Assets 

Case Title :  VOIZZIT TECHNOLOGY PVT. LTD. AND ANR. vs. CLAUDIA Z. SPRINGER AND ORS. 

Case Number :  Diary No. - 37048/2026

Two companies claiming rights over BYJU'S US subsidiaries, Epic Creations Inc. and Tangible Play Inc., have approached the Supreme Court against a Kerala High Court judgment that removed a US bankruptcy trustee from a commercial suit filed in Ernakulam.

Supreme Court Issues Notice On Plea Against NCLAT Relief To Former Deccan Chronicle Promoter 

Case Title :  L AND T FINANCE LIMITED Versus T. VENKATRAM REDDY AND ANR. 

Case Number :  C.A. No. 8371/2026

The Supreme Court on Thursday issued notice in a plea filed by L&T Finance Ltd challenging an NCLAT order that set aside bankruptcy proceedings against former Deccan Chronicle Holdings Limited promoter and personal guarantor T. Venkatram Reddy.

The bankruptcy proceedings had been set aside by NCLAT on April 2, 2026, after the appellate tribunal on the same date quashed the underlying personal insolvency proceedings initiated against Reddy under Section 95 of the Insolvency and Bankruptcy Code, holding them to be barred by limitation.

HIGH COURT 

Directions To NCLT For Urgent Listing Of Plea Cannot Be Issued In Writ Jurisdiction: Delhi High Court 

Case Title :  ANUJ GOYAL vs NATIONAL COMPANY LAW TRIBUNAL AND ORS. T HROUGH REGISTRAR 

Case Number :  W.P.(C) 8240/2026 

CITATION :  2026 LLBiz HC (DEL) 628

The Delhi High Court has recently refused to issue directions to the National Company Law Tribunal (NCLT) for urgent listing of a homebuyer's transfer plea in an ongoing insolvency proceeding. The court observed that such directions cannot be issued in exercise of its writ jurisdiction. A vacation bench of Justice Tejas Karia dismissed a petition filed by homebuyer Anuj Goyal and imposed costs of ₹25,000, payable to the Delhi High Court Bar Clerks' Association within two weeks.

Orissa High Court Quashes Criminal Proceedings Against Ferro Alloys Over Pre-CIRP Environmental Law Violations 

Case Title :  Ferro Alloys Corporations Ltd.-versus- Sub Divisional Magistrate, Champua & Anr. 

Case Number :  CRLMC No. 5590 of 2025 

CITATION :  2026 LLBiz HC (ORI) 21

The Orissa High Court has recently quashed criminal proceedings against Ferro Alloys Corporation Ltd over alleged environmental law violations.  It held that continuation of the prosecution was not sustainable as the violations happened before the insolvency resolution. Justice Dr. Sanjeeb K. Panigrahi also noted that offences under Section 15 of the Environment (Protection) Act, 1986 have since been decriminalised. They have been replaced with a regime of civil penalties.

NCLAT 

NCLAT Holds Appeal E-Filed At 9 PM On Last Condonable Day Within Limitation 

Case Title :  Acrow Realcon Pvt. Ltd. & Ors. v. Union Bank of India & Ors. 

Case Number :  I.A. Nos. 2936, 2937, 2938 & 2939 of 2026 in Company Appeal (AT) (Insolvency) Nos. 755-758 of 2026 

CITATION :  2026 LLBiz NCLAT 251

The National Company Law Appellate Tribunal (NCLAT) in Delhi has held that an insolvency appeal filed electronically at 9 PM on the last day of the condonable period cannot be treated as time-barred merely because it was filed after the tribunal's working hours.

Going Concern Sale Does Not Transfer Subsidiaries Outside Liquidation Estate: NCLAT 

Case Title :  RAGHAVA SQUARE PRIVATE LIMITED Vs IVRCL LIMITED & Ors 

Case Number :  Company Appeal (AT) (Insolvency) 93/2025 & 96/2025, 309/2024, 310/2024

CITATION :  2026 LLBiz NCLAT 252

he National Company Law Appellate Tribunal (NCLAT) in Chennai has recently held that a purchaser of a corporate debtor sold as a going concern in liquidation cannot claim rights over its subsidiaries, joint ventures, or associate entities merely because they belong to the same corporate group. The tribunal ruled that such assets fall outside the liquidation estate and do not automatically pass to the successful bidder.

NCLAT Upholds NCLT Order Asking CoC To Consider Prior Judicial Observations On RP Before Appointment 

Case Title :  TSN Raja 

Case Number :  Company Appeal (AT) (Insolvency) 264/2026 & 265/2026 

CITATION :  2026 LLBiz NCLAT 253

The National Company Law Appellate Tribunal (NCLAT) in Chennai has refused to interfere with an order directing the Committee of Creditors (CoC) to consider adverse observations made against an insolvency professional in an earlier proceeding. The observations were to be considered before proceeding with approval of his appointment as Resolution Professional in two corporate insolvency cases. A bench of Justice Sharad Kumar Sharma and Technical Member Jatindranath Swain observed that the National Company Law Tribunal (NCLT) Hyderabad's direction was only precautionary in nature. It did not finally determine any rights.

Insolvency Professional Can Continue Existing Assignments After Attaining Age 70: NCLAT 

Case Title :  Chavva Naga Sampathi Tayaru Vs Sri Ananda Lakshmi Narasimha Industries India Pvt Ltd & Central Bank of India 

Case Number :  Company Appeal (AT) (Insolvency) 261/2026 & 260/2026 

CITATION :  2026 LLBiz NCLAT 254

The National Company Law Appellate Tribunal (NCLAT) at Chennai has held that an insolvency professional can continue handling assignments already entrusted to him even after turning 70 years of age, the upper age limit for insolvency professionals, if the Authorisation for Assignment (AFA) expires during the course of those assignments. LLP Legal Services

NCLT 

NCLT Ahmedabad Rejects CIRP Plea Against Sisa Mosaic, Says Petition May Be Collusive And MOU Appears Fictitious 

Case Title :  Gayatri Engimech Private Limited Vs Sisa Mosaic Private Limited 

Case Number :  C.P.(IB)/250(AHM)2025 

CITATION :  2026 LLBiz NCLT (AHM) 575

The Ahmedabad bench of the National Company Law Tribunal (NCLT) has rejected an insolvency application, holding that the petition may be collusive. The tribunal also observed that the Memorandum of Understanding (MOU) relied upon by the applicant appeared to be a fictitious document created for filing the case. The application was filed by Gayatri Engimech Pvt. Ltd. against Sisa Mosaic Pvt. Ltd. seeking initiation of the corporate insolvency resolution process over an alleged default of ₹3.58 crore arising from an unsecured loan transaction.

NCLT Delhi Dissolves Company Despite ₹100.20 Crore GST Demand, Preserves Proceedings Against Directors 

Case Title :  Montage Enterprises Pvt Ltd. Versus M/s Neemsar Vyapaar Pvt. Ltd. Limited Case Number :  IA (Dis.)-21(ND)/2024 In IB-716(ND)/2022 

CITATION :  2026 LLBiz NCLT(DEL) 578

The National Company Law Tribunal (NCLT) at Delhi has recently ordered the dissolution of Neemsar Vyapaar Private Limited after finding no impediment to doing so, even though a GST demand of ₹100. 20 crore had been raised against the company during the liquidation process. A bench of Judicial Member Bachu Venkat Balaram Das and Technical Member Ravindra Chaturvedi observed that there was no impediment to dissolution, clarifying that proceedings could continue against persons concerned with the company.

NCLT Delhi Approves ₹1.89 Crore Repayment Plan For Woolways India Personal Guarantor 

Case Title :  SBI v.. Babita Nayar 

Case Number :  IA-3478/2024 IN IB-696(ND)/2021 

CITATION :  2026 LLBiz NCLT(DEL) 579

The National Company Law Tribunal (NCLT) at Delhi has approved a repayment plan worth ₹1.89 crore proposed by Babita Nayar, personal guarantor to Woolways India Limited. The plan envisages repayment to creditors within five months through the sale of immovable properties and financial assistance from friends and relatives. A bench of Judicial Member Bachu Venkat Balaram Das and Technical Member Ravindra Chaturvedi also clarified, in a connected matter, that an earlier direction requiring the State Bank of India (SBI) to deposit ₹2 lakh into the account of the Resolution Professional was only an interim measure intended to facilitate the insolvency process. It was not a determination of the final professional fee payable.

NCLT Chandigarh Orders Eviction Of Related Parties From Venus Garments Assets, Backs Liquidator Under IBC 

Case Title :  Pramod Kumar Misra Vs M/S DUKE FASHIONS (INDIA) LTD. 

Case Number :  I.A. No. 1975 of 2023 & I.A. No. 1991 of 2023 in CP (IB) NO. 66/CHD/PB/2019 

CITATION :  2026 LLBiz NCLT(CHA) 580

On 11 June, the Chandigarh Bench of the National Company Law Tribunal (NCLT), held that the Liquidator under the Insolvency and Bankruptcy Code, 2016 (IBC) has overriding authority to recover possession of liquidation estate assets, and that rent control proceedings cannot obstruct such statutory duties. Judicial Member Khetrabasi Biswal and Technical Member Shishir Agarwal directed Duke Fashions (India) Ltd. and UV & W Products Pvt. Ltd. to vacate and hand over possession of prime properties in Ludhiana forming part of the liquidation estate of Venus Garments (India) Limited.

NCLT Bengaluru Allows Change In Default Date In Insolvency Plea Against Cafe Coffee Day Parent 

Case Title :  Reschtsanwalt Dr.Christian Bachmann v. Coffee Day Global Limited 

Case Number :  IA No. 722 of 2025 in CP(IB) No. 232/BB/2024 

CITATION :  2026 LLBiz NCLT(BEN) 584

The National Company Law Tribunal (NCLT) at Bengaluru recently allowed an amendment to the date of default in an insolvency petition against Cafe Coffee Day parent Coffee Day Global Ltd, permitting the date to be changed from November 27, 2020, to September 30, 2019.  A bench of Judicial Member Sunil Kumar Aggarwal and Technical Member Radhakrishna Sreepada held that the proposed amendment merely aligned the date of default with the factual foundation already set out in the pleadings and did not amount to introducing a new cause of action.

NCLT Delhi Rejects Former SpiceJet Pilot's Insolvency Plea Against Airline Over Salary Dues 

Case Title :  CAPT. DEVESH BBYAN Vs SPICEJET LIMITED 

Case Number :  C.P. (IB)-148/ND/2025 

CITATION :  2026 LLBiz NCLT(DEL) 585

The National Company Law Tribunal (NCLT) at Delhi has recently dismissed an insolvency plea filed by a former SpiceJet pilot over alleged unpaid salary dues, holding that the claim fell below the minimum threshold required for initiating insolvency proceedings and was also the subject of a pre-existing dispute

Family Settlement Excluding Legal Heirs, Coparceners Cannot Defeat Oppression Petition: NCLT Kolkata: 

Case Title :  Ram Niranjan Kajaria & Ors. v. Anil Plantations Private Limited & Ors. 

Case Number :  IA (Companies Act)/144/KB/2025; COMP. APPL. 43/KB/2024

CITATION :  2026 LLBiz NCLT (KOL) 586

The National Company Law Tribunal (NCLT) in Kolkata has held that family settlement agreements entered into by only some members of a family cannot be recognised as binding settlements where other legal heirs and coparceners continue to assert rights in the disputed estate and shareholding. The tribunal ruled that two such agreements relied upon in a dispute concerning Anil Plantations Private Limited were void and illegal. It further held that the agreements could not render the company petition non-maintainable.

Corporate Debtor Cannot Be Sold As Going Concern After Omission Of Enabling Liquidation Provisions: NCLT Kolkata 

Case Title :  Sanjeev Jhunjhunwala, Liquidator of Dooteriah & Kalej Valley Tea Private Limited v. Goutam Kumar Roy & Anr. 

Case Number :  I.A. (IB) No. 27/KB/2026 in C.P. (IB) No. 557/KB/2017 

CITATION :  2026 LLBiz NCLT (KOL) 587

The National Company Law Tribunal (NCLT), Kolkata Bench, has recently held that after the omission of the provisions permitting going-concern sales under the Insolvency and Bankruptcy Board of India (Liquidation Process) Regulations, 2016, it cannot allow the sale of a corporate debtor as a going concern or as a continuing juristic entity during liquidation.

NCLT Kochi Declines Temple Trust's Bid For Possession Of Property Leased To Attukal Devi Institute During CIRP 

Case Title :  Attukal Bhagavathy Temple Trust & Anr. v. Attukal Devi Institute of Medical Sciences Ltd. & Anr. 

Case Number :  IA(IBC)/217/KOB/2025 in CP(IBC)/22/KOB/2024 

CITATION :  2026 LLBiz NCLT (KOB) 591

The National Company Law Tribunal (NCLT) at Kochi has recently refused to direct the Resolution Professional to hand over possession of a hospital property leased by Attukal Bhagavathy Temple Trust to Attukal Devi Institute of Medical Sciences Ltd., observing that such a direction could not be issued during the subsistence of the Corporate Insolvency Resolution Process (CIRP) and moratorium. The tribunal observed that such a direction could not be issued while the Corporate Insolvency Resolution Process (CIRP) and moratorium remained in force.

NCLT Hyderabad Refuses To Direct VNR Infrastructure Liquidator To Process Subcontractor's Bills 

Case Title :  SS Rail Works Pvt. Ltd. v. VNR Infrastructure Ltd. (Under Liquidation) 

Case Number :  IA No. 44 of 2022 in CP (IB) No. 12/10/HDB/2017 

CITATION :  2026 LLBiz NCLT (HYD) 592

The National Company Law Tribunal (NCLT) at Hyderabad has refused to direct the liquidator of VNR Infrastructure Ltd. to process a subcontractor's bills and secure payment from North East Frontier Railway authorities.

Proceedings Before Calcutta High Court No Bar To Examining Preferential Transactions: NCLT Kolkata 

Case Title :  McNally Bharat Engineering Company Limited Through its Resolution Professional Mr. Ravi Sethia … Resolution Professional/Applicants Versus McNally Trolex JV & Ors 

Case Number :  I.A. (IB) No. 342/KB/2023 In Company Petition (IB) No. 891/KB/2020

CITATION :  2026 LLBiz NCLT (KOL) 595

The Kolkata Bench of the National Company Law Tribunal (NCLT) on 12 June held that the mere pendency of proceedings before the Calcutta High Court does not prevent it from examining whether a transaction amounts to a preferential transaction under Section 43 of the Insolvency and Bankruptcy Code, 2016.

NCLT Ahmedabad Directs Return Of 5 EVs To Gensol EV Lease, Bars Arbitration During Moratorium 

Case Title :  Keshav Khaneja RP of Gensol EV Lease Limited Vs EC Wheels India Private Limited 

Case Number :  IA/1429(AHM)2025 In C.P.(IB)/199(AHM)2025 

CITATION :  2026 LLBiz NCLT (AHM) 596

The Ahmedabad Bench of the National Company Law Tribunal (NCLT) on 15 June held that leased vehicles forming part of a corporate debtor's assets must be returned to the Resolution Professional during insolvency proceedings. Further, that rival monetary claims cannot be decided in summary jurisdiction under Section 60(5) of the Insolvency and Bankruptcy Code (IBC).

Auction Reliefs Under IBC Restricted To Successful Bidder, Not Post-Acquisition Investors: NCLT Hyderabad 

Case Title :  Frontline Wind Energy Private Limited v. K. Vatsa Kumar, Liquidator of PPS Enviro Power Private Limited & Anr. 

Case Number :  IA (IBC) No. 239 of 2026 in CP (IB) No. 407/7/HDB/2018 

CITATION :  2026 LLBiz NCLT (HYD) 593

The Hyderabad Bench of the National Company Law Tribunal (NCLT) has held that reliefs and concessions arising from a liquidation auction conducted on a going-concern basis cannot extend directly to third-party investor entities who did not participate in the bidding process or receive auction documents.

NCLT Mumbai Rejects Insolvency Plea Against Eros Over Claim Arising From 'NH10' Co-Production Agreement. 

Case Title :  Phantom Studios India Private Limited vs EROS International Media Limited

Case Number :  C.P. No. (IB) 598/MB/C-III/2024 

CITATION :  2026 LLBiz NCLT (MUM) 599

The Mumbai Bench of the National Company Law Tribunal (NCLT) has dismissed an insolvency plea filed by Phantom Studios India Pvt Ltd against Eros International Media Ltd. The Tribunal held that Phantom Studios' claim for ₹1.48 crore arising from the parties' co-production arrangement for the film NH10 did not qualify as an operational debt under the Insolvency and Bankruptcy Code. A bench of Judicial Member Lakshmi Gurung and Technical Member Hariharan Neelakanta Iyer rejected Phantom Studios' petition seeking initiation of the corporate insolvency resolution process against Eros over an alleged default of Rs 1.48 crore.

NCLT Ahmedabad Admits Insolvency Plea Against Evoq Remedies Over ₹1.95 Crore Unrefunded Advance 

Case Title :  Harbhole Agrotech Vs Evoq Remedies Limited 

Case Number :  CP (IB) No.149/9/AHM/2026 

CITATION :  2026 LLBiz NCLT (AHM) 600

The Ahmedabad bench of the National Company Law Tribunal (NCLT) has admitted Harbhole Agrotech's insolvency petition against Evoq Remedies Limited over an alleged default in refunding Rs 1.95 crore paid in advance for the supply of FSG Castor Oil. A bench of Judicial Member Shammi Khan and Technical Member Sanjeev Sharma found that the debt and default had been established. It also found that no pre-existing dispute had been shown on record.

Only Security Created Over Corporate Debtor's Assets Confers Secured Creditor Status: NCLT Kochi 

Case Title :  Dileep K.P v. YES Bank Limited 

Case Number :  IA(IBC)/138/KOB/2026 in CP(IBC)/33/KOB/2025 

CITATION :  2026 LLBiz NCLT(KOC) 602

The National Company Law Tribunal (NCLT) at Kochi has held that a creditor cannot claim the status of a secured financial creditor in a corporate insolvency resolution process merely because its debt is backed by the personal assets of promoters.

NCLT Chandigarh Denies Financial Creditor Status To Samar Estates Flat Buyers After Allotment Cancellation 

Case Title :  Radhey Sham Midha & Sandeep Kumar Bhatla Vs Rahul Jindal 

Case Number :  I.A.(I.B.C)/46(CH)/2025 in CP (IB) No. 98/Chd/Hry/2022 

CITATION :  2026 LLBiz NCLT(CHA) 590

The Chandigarh Bench of the National Company Law Tribunal (NCLT) has dismissed a plea by two flat buyers seeking recognition as financial creditors of Samar Estates Pvt. Ltd. and inclusion in the company's Committee of Creditors (CoC).

NCLT Kochi Holds 2026 IBC Amendment Clarifying Liquidation Distribution Applies Retrospectively 

Case Title :  Meenachil East Urban Co-operative Bank Limited v. CA Mahalingam Suresh Kumar and Anr 

Case Number :  IA(IBC)/1/KOB/2025 in IBA/240/KOB/2019 

CITATION :  2026 LLBiz NCLT(KOC) 603

The National Company Law Tribunal (NCLT) has ruled that a 2026 clarification to the insolvency law governing the entitlement of secured creditors who relinquish their security interests during liquidation applies to pending proceedings.

Income Tax Department Cannot Continue Pre-CIRP Attachment After Resolution Plan Approval: NCLT Kochi 

Case Title :  Orchid Valley Apartment Buyers Association v. Assistant Commissioner of Income Tax Circle and Anr 

Case Number :  MA(IBC)/02/KOB/2026 in IA(IBC)/215/KOB/2023 in CP(IB)/05/KOB/2021

CITATION :  2026 LLBiz NCLT(KOC) 605

The National Company Law Tribunal (NCLT) at Kochi recently held that the Income Tax Department cannot continue a pre-CIRP attachment over a corporate debtor's property after approval of a resolution plan. A coram of Judicial Member Vinay Goel and Technical Member Ravichandran Ramasamy allowed an application filed by Orchid Valley Apartment Buyers Association, the successful resolution applicant for the Orchid Valley project of Samson and Sons Builders and Developers Private Limited.

Tribunal Cannot Expand Asset Base After Approval of Resolution Plan Under Section 31: NCLT Guwahati 

Case Title :  PRAG India vs Ms. Sudha Sharma 

Case Number :  IA(IBC)/23/GB/2026 in IA(IBC)(PLAN) 1/GB/2025 in CP(IB)/128/GB/2018

CITATION :  2026 LLBiz NCLT(GUA) 607

The Guwahati Bench of the National Company Law Tribunal (NCLT) on 12 June held that once a resolution plan is approved under Section 31 of the Insolvency and Bankruptcy Code, it cannot be used to rewrite, modify or expand the asset base contemplated under the plan.

NCLT Mumbai Admits Central Bank Of India's ₹44.68 Crore Insolvency Plea Against Deepak Education 

Case Title :  CENTRAL BANK OF INDIA vs DEEPAK EDUCATION LIMITED 

Case Number :  CP (IB) No. 374/MB/2024 

CITATION :  2026 LLBiz NCLT (MUM) 608

On 17 June, the Mumbai Bench of the National Company Law Tribunal (NCLT) admitted a Section 7 petition filed by Central Bank of India against Deepak Education Ltd over a default of Rs. 44.68 crore, thereby initiating the Corporate Insolvency Resolution Process against the company. 

NCLT Delhi Holds Homebuyers' Payments Are Financial Debt, Admits ₹137 Cr Plea In Raheja's Revanta Project 

Case Title :  Surinder Aggarwal & Ors. Vs Raheja Developers Limited 

Case Number :  CP (IB) – 182(ND)/2024 

CITATION :  2026 LLBiz NCLT(DEL) 610

The New Delhi National Company Law Tribunal (NCLT) on 8 June held that homebuyers' payments towards a real estate project constitute financial debt under Section 5(8)(f) of the Insolvency and Bankruptcy Code (IBC).  President Justice Anupinder Singh Grewal and Technical Member Ravindra Chaturvedi admitted a Section 7 petition filed by 176 allottees of Raheja Developers' Revanta project seeking initiation of the Corporate Insolvency Resolution Process (CIRP) against the developer.

NCLT Chandigarh Allows Liquidator To Initiate Execution Proceedings For Enhanced Land Acquisition Compensation 

Case Title :  Rajesh Kumar Loomba, Liquidator of Julka Rice and Oil Mills Limited v. Julka Rice and Oil Mills Limited (Under Liquidation) 

Case Number :  IA (IBC) 585(CH)/2026 in CP (IB) No. 38/Chd/Pb/2018 

CITATION :  2026 LLBiz NCLT (CHA) 604

The National Company Law Tribunal (NCLT) at Chandigarh has allowed the liquidator of a rice mill to initiate execution proceedings for recovery of enhanced compensation awarded for land acquired by the Punjab government.

Collusion Allegations Alone Cannot Establish Fraudulent Insolvency Proceedings: NCLT Chandigarh 

Case Title :  Dr. Vijay Vohra v. Himalaya Food International Ltd. 

Case Number :  IA (IBC) No. 900/CH/2025 in CP (IB) No. 161/Chd/HP/2023 

CITATION :  2026 LLBiz NCLT(CHA) 612

The National Company Law Tribunal (NCLT) in Chandigarh has held that allegations of collusion, related-party dealings, and disputes among shareholders or directors are not enough to establish that insolvency proceedings were initiated fraudulently.  A bench of Judicial Member Khetrabasi Biswal and Technical Member Kaushalendra Kumar Singh rejected an application filed by Dr Vijay Vohra, a promoter shareholder and director of A.P.J. Laboratories Ltd.

Settlement In Corporate Debtor's Liquidation Does Not Extinguish Personal Guarantee Obligations: NCLT Chennai 

Case Title :  Aditya Birla Finance Limited v. G. Thiyagarajan 

Case Number :  CP(IB)/43(CHE)/2024 and IA(IBC)/799(CHE)/2024 

CITATION :  2026 LLBiz NCLT(CHE) 613

The National Company Law Tribunal (NCLT) at Chennai has reiterated that a settlement reached during the liquidation of a corporate debtor does not absolve a personal guarantor of liability under a separate contract of guarantee.

NCLT Mumbai Admits Paytm Parent's Insolvency Plea Against Gaming Company Fabzen Over ₹3.41 Crore Dues 

Case Title :  One 97 Communication Limited vs Fabzen Technologies Private Limited

Case Number :  C.P. (IB)/884(MB)2025 

CITATION :  2026 LLBiz NCLT (MUM) 615

The National Company Law Tribunal (NCLT) in Mumbai has admitted an insolvency plea filed by One97 Communications Ltd, which operates Paytm, against gaming company Fabzen Technologies Pvt Ltd over unpaid dues of more than ₹3.41 crore for digital advertising services.  A bench of Judicial Member Nilesh Sharma and Technical Member Sameer Kakar held that One97 had established the existence of an operational debt and a payment default, while Fabzen had failed to show any pre-existing dispute.

Bare Production Of Guarantee Deed Without Commercial Nexus Cannot Establish Debt: NCLT Mumbai 

Case Title :  Naman Syntex Prop Daksha Rajendra Ahuja. Versus Mrs. Mansi Lalit Kumar Manjrekar 

Case Number :  CP (IB) No.970/MB/2025 

CITATION :  2026 LLBiz NCLT (MUM) 619

The Mumbai Bench of the National Company Law Tribunal on 16 June held that a Section 95 insolvency petition under the Insolvency and Bankruptcy Code cannot be sustained on the basis of a mere guarantee deed without supporting evidence of commercial context, consideration, financial capacity and nexus establishing a legally enforceable debt.

NCLT Ahmedabad Admits CIRP Against JSW Subsidiary, Holds Guarantor Liability Co-extensive With Borrower 

Case Title :  Krishkan Investment Private Limited. Vs Utkal Steels Limited 

Case Number :  TP(IBC)/2(AHM)2026 

CITATION :  2026 LLBiz NCLT (AHM) 621

The Ahmedabad Bench of the National Company Law Tribunal (NCLT) on 17 June held that insolvency proceedings against a corporate guarantor cannot be made conditional on the realisation of assets of the principal borrower and reaffirmed that a guarantor's liability remains co-extensive with that of the principal debtor under Section 128 of the Indian Contract Act, 1872.

CoC Cannot Claim Net Gain From Subsequent Land Acquisition After Approving Resolution Plan: NCLT Mumbai 

Case Title :  Edelweiss Asset Reconstruction Company Ltd. v/s. Fab Metals Private Limited & Ors 

Case Number :  I.A. No. 3983 of 2024 IN C.P. (IB) No. 1224/MB/2020 

CITATION :  2026 LLBiz NCLT (MUM) 624

The National Company Law tribunal (NCLT) at Mumbai has held that creditors cannot claim the benefit of a subsequent increase in the value of a corporate debtor's assets after approving a resolution plan. The tribunal ruled that the gain cannot be claimed merely because the increase was not contemplated when the plan was approved.

Insolvency Against Personal Guarantor Maintainable Without CIRP Against Borrower: NCLT Kolkata 

Case Title :  Indian Bank Versus Santosh Jhawar, Personal Guarantor of M/s Burgundy Life Style Pvt. Ltd 

Case Number :  I.A. (IB) No. 1690/KB/2024 In C.P. (IB) No. 193/KB/2024 

CITATION :  2026 LLBiz NCLT (KOL) 627

The National Company Law Tribunal (NCLT) at Kolkata has reiterated that insolvency proceedings against a personal guarantor can be maintained even if no insolvency proceedings have been initiated against the principal borrower.

NCLT Bengaluru Holds Bank Cannot Retain Title Deeds After Full Payment of Resolution Plan Dues 

Case Title :  Kotak Mahindra Bank v. Arun Shelters 

Case Number :  IA(IBC) 1002/ 2025 in CP(IB) No. 305/BB/2019 

CITATION :  2026 LLBiz NCLT (BEN) 628

The National Company Law Tribunal (NCLT) at Bengaluru has held that a bank that has received the full amount payable under an approved resolution plan cannot continue withholding a corporate debtor's title deeds and security documents. The tribunal held that the pendency of an appeal concerning an interest dispute is not, by itself, a valid reason to retain those documents. A bench of Judicial Member Sunil Kumar Aggarwal and Technical Member Radhakrishna Sreepada directed Kotak Mahindra Bank to hand over the original title deeds, security papers and charge release documents relating to the Arun Aurovilla project within 15 days.

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