LiveLawBiz Company Law Digest : September 2026
Shilpa Soman
1 Oct 2026 12:50 PM IST
SUPREME COURT
The Supreme Court on Monday held that identification of a natural person is not a prerequisite, at the threshold stage, for prosecuting a corporate entity for an offence involving mens rea.
Case Title : Sanofi India Ltd v. Central Bureau of Investigation
Case Number : Criminal Appeal No. 4250 of 2026
CITATION : 2026 LLBiz SC 298
Supreme Court Refuses To Interfere With NCLAT Order In 35-Year-Old Peerless Shareholder Dispute
The Supreme Court has refused to interfere with the National Company Law Appellate Tribunal's order setting aside the National Company Law Tribunal, Kolkata's decision.
The NCLT had cancelled the allotment of 30,000 equity shares by Peerless General Finance & Investment Co Ltd (PGFI) to three companies allegedly connected with the Roy-Sen group, as well as the subsequent transfer of 15,626 shares.
Case Title : BHAGWATI DEVELOPERS PVT. LTD. VS. THE PEERLESS GENERAL FINANCE AND INVESTMENT CO. LTD.
Case Number : C.A. No. 008758 - 008760 / 2026
CITATION : 2026 LLBiz SC 301
Supreme Court Issues Notice On Plea Against NCLAT Ruling On NCLT Power To Order EGM
The Supreme Court on Tuesday issued notice on a plea challenging the National Company Law Appellate Tribunal's August 17, 2026 order.
The NCLAT held that the NCLT cannot direct the convening of an Extraordinary General Meeting under Section 98 of the Companies Act, 2013, unless the applicant establishes that holding the meeting without the Tribunal's intervention has become impracticable.
Case Title : HIRAS K M VS. MS PEARL CITY MARINE PRODUCTS PRIVATE LIMITED
Case Number : DIARY NO. - 53533/2026
The Supreme Court has recently clarified that the Centre can authorise any Central Government officer, in addition to the Director of the Serious Fraud Investigation Office (SFIO), to institute a complaint under the second proviso to Section 212(6) of the Companies Act.
Case Title : UNION OF INDIA VERSUS THE STATE OF TELANGANA & ORS.
Case Number : R.P.(Crl.) No.470/2026 in Crl.A. No.147/2026
CITATION : 2026 LLBiz SC 317
Supreme Court Stays NCLAT Order Reviving IL&FS Plea Over ₹1,080 Crore SREI Group Linked Transactions
The Supreme Court on Monday stayed the operation of the National Company Law Appellate Tribunal (NCLAT) order reviving Infrastructure Leasing & Financial Services Ltd. (IL&FS)'s plea seeking to unwind six alleged circuitous lending transactions worth ₹1,080 crore involving SREI Infrastructure Finance Limited (SIFL) group entities.
Case Title : SREI INFRASTRUCTURE FINANCE LIMITED VS. INFRASTRUCTURE LEASING AND FINANCIAL SERVICES LIMITED
Case Number : DIARY NO. - 50578/2026
HIGH COURT
Delhi High Court Refuses To Quash Criminal Case Against Supertech Directors Over Hill Town Project
The Delhi High Court has refused to quash criminal proceedings against directors of real estate company Supertech Limited over allegations of cheating, criminal breach of trust and criminal conspiracy linked to its Hill Town project in Sohna, Haryana.
Case Title : Sangita Arora v. State of NCT Delhi and Anr
Case Number : Crl.M.C No. 4722 of 2026
CITATION : 2026 LLBiz HC(DEL) 948
The Calcutta High Court on Wednesday stayed a Serious Fraud Investigation Office (SFIO) investigation into alleged financial irregularities involving funds of an exempted provident fund Trust operated by Hindusthan National Glass and Industries Limited (HNGIL) for its employees.
Case Title : SANJAY SOMANY AND ORS. VS HINDUSTHAN NATIONAL GLASS AND INDUSTRIES LIMITED (HNGIL) AND ORS. Case Number : APO/56/2026 CITATION : 2026 LLBiz HC (CAL) 223
On Monday, 28 September, the Calcutta High Court held that an arbitration clause contained in a company's Articles of Association operates as an independent agreement and does not make disputes covered by the clause subject exclusively to the jurisdiction of the National Company Law Tribunal (NCLT).
Case Title : Ambica Beri v. Forum Atmosphere Flat Owner's Association
Case Number : FMAT No. 342 of 2026
CITATION : 2026 LLBiz HC(CAL) 235
NCLAT
Notices To ED, CBI For Investigating Company Affairs Can Be Issued Only After Hearing Parties: NCLAT
The National Company Law Appellate Tribunal (NCLAT) at Delhi has ruled that an investigation into a company's affairs cannot be initiated merely because an application has been filed.
The tribunal must first satisfy itself that the circumstances required under Section 213(b) of the Companies Act exist. It must also give the affected parties a reasonable opportunity to hear.
Case Title : Salma Moosa & Srinivasan Vivek Vs Akarappu Om Yeshwanth & Ors
Case Number : Company Appeal (AT) 55/2026
CITATION : 2026 LLBiz NCLAT 344
NCLAT Delhi Says Counsel's Personal Difficulties Cannot Explain Appellant's 202-Day Refiling Delay
On 18 September, the National Company Law Appellate Tribunal (NCLAT) at New Delhi held that an appellant cannot rely on the personal difficulties of his counsel to explain his own failure to rectify Registry defects and seek condonation of a 202-day delay in refiling an appeal.
Case Title : RAJENDRA DEVIDAS PURANIK
Case Number : Company Appeal (AT) (Insolvency) 326/2026
CITATION : 2026 LLBiz NCLAT 361
Conversion of IBC Appeal Into Companies Act Appeal Does Not Save Limitation: NCLAT
The National Company Law Appellate Tribunal (NCLAT) at Delhi has recently held that an appeal filed under the insolvency law does not provide continuity for limitation when it is transformed into an appeal under the company law.
Case Title : Anjaniputra Ispat Ltd. Vs IAG Company Ltd & Trust Estate Khimji Keshwaji
Case Number : Company Appeal (AT) 39/2026
CITATION : 2026 LLBiz NCLAT 363
The National Company Law Appellate Tribunal (NCLAT) at Delhi has cut from ₹10 lakh to ₹5 lakh the cost imposed on a company while restoring its name to the Register of Companies.
It held that the higher amount was disproportionate and was not supported by any determination of the actual costs incurred in the appeal or application.
Case Title : Ganton Projects Private Limited & Ravindra Singh Chauhan Vs RoC & Commissioner of Income Tax
Case Number : Company Appeal (AT)176 /2026
CITATION : 2026 LLBiz NCLAT 362
The National Company Law Appellate Tribunal (NCLAT) Chennai has set aside an order of the National Company Law Tribunal (NCLT) Amravati Bench rejecting the first motion application for the proposed merger of Hinduja National Power Corporation Ltd. (HNPCL) with GOCL Corporation Ltd.
Case Title : HINDUJA NATIONAL POWER CORPORATION LIMITED & GOCL CORPORATION LIMITED Vs THE REGIONAL DIRECTOR & RoC
Case Number : Company Appeal (AT) (CH) 88/2026
CITATION : 2026 LLBiz NCLAT 371
Commercial Necessity Cannot Override Oppression Claims, NCLAT New Delhi Tells NCLT
On 25 September, the National Company Law Appellate Tribunal (NCLAT) at New Delhi held that a company's claim that a restructuring was commercially necessary or undertaken to address financial exigencies cannot by itself relieve the National Company Law Tribunal (NCLT) of its duty to examine allegations of oppression and mismanagement.
Case Title : Nikhil Rai & Ors Vs Vcare Technologies Private Limited & Ors
Case Number : Company Appeal (AT) No. 280/ 2026
CITATION : 2026 LLBiz NCLAT 372
NCLT
NCLT Indore Admits Second Motion In Composite Scheme Of HEG Demerger and Bhilwara Energy Merger
The Indore Bench of the National Company Law Tribunal (NCLT) has sanctioned a composite scheme of arrangement involving HEG Ltd, HEG Graphite Ltd and Bhilwara Energy Ltd under Sections 230 to 232 of the Companies Act, 2013.
Case Title : HEG Ltd, HEG Graphite Ltd and Bhilwara Energy Ltd
Case Number : CP(CAA)/3(MP)2026 in CA(CAA)/1(MP)2026
CITATION : 2026 LLBiz NCLT(IND) 850
NCLT Ahmedabad Sanctions Essar Scheme, Approves Brand Demerger And ₹875 Crore CCPS Restructuring
The Ahmedabad Bench of the National Company Law Tribunal (NCLT) on 31 August sanctioned a composite scheme of arrangement providing for the demerger of the brand undertaking of Abhinand Ventures Pvt. Ltd. (AVPL) into Essar Power Ltd. (EPOL), along with restructuring of EPOL's 0.01% Compulsory Convertible Cumulative Preference Shares (CCPS).
Case Title : Abhinand VenturesPvt. Ltd & Essar Power Limited
Case Number : C.P.(CAA)22/(AHM)2026 in C.A.(CAA)/1(AHM)2026
CITATION : 2026 LLBiz NCLT (AHM) 857
NCLT Mumbai Allows First Motion For Amalgamation Of Tata Motors' Wholly Owned Subsidiaries With It
The National Company Law Tribunal at Mumbai has allowed the first motion application for the proposed amalgamation of Tata Motors Limited's direct and indirect wholly owned subsidiaries, TMF Holdings Limited and TMF Business Services Limited, with Tata Motors.
Case Title : Tata Motors Limited (Amalgamated Company/Applicant Company-1) and TMF Holdings Limited (Amalgamating Company-1/Applicant Company-1) and TMF Business Services Limited (Amalgamating Company-2/Applicant Company-3) and and their respective Shareholders.
Case Number : CA(CAA)/113/MB/2026
CITATION : 2026 LLBiz NCLT (MUM) 859
NCLT Chennai Directs Meetings For California Burrito Merger With Burrito Restaurants
The National Company Law Tribunal (NCLT) at Chennai recently allowed an application in connection with the proposed amalgamation of California Burrito, a Singapore-incorporated Mexican food chain, with Burrito Restaurants Private Limited.
Case Title : California Burrito Pte Ltd v. Burrito Restaurants Private Limited
Case Number : CA(CAA)/60(CHE)/2026
CITATION : 2026 LLBiz NCLT(CHE) 864
The National Company Law Tribunal (NCLT) at Bengaluru has held that the absence of an express provision for impleading third parties under Section 131 of the Companies Act, 2013 does not curtail its inherent powers under Rule 11 of the NCLT Rules, 2016 to permit the participation of persons necessary for effective adjudication. Section 131 permits a company to revise its financial statements or Board's report when they do not comply with the provisions of the Act.
Case Title : Mr. Altaf Pasha and Ors v. Imperio Hospitality Pvt Ltd
Case Number : CA No. 44/BB/2026
CITATION : 2026 LLBiz NCLT(BEN) 868
NCLT Guwahati Dismisses Department's Sapphire Suppliers Restoration Plea, Says NCLAT Appeal Pending
The National Company Law Tribunal (NCLT) at Guwahati has dismissed the Income Tax Department's petition seeking restoration of Sapphire Suppliers Private Limited, holding that the issue was already pending before the National Company Law Appellate Tribunal (NCLAT) and that proceeding with the petition could lead to conflicting decisions and multiplicity of proceedings.
Case Title : Department of Income Tax v. Sapphire Suppliers Private Limited and Anr
Case Number : CP/7/GB/2026
CITATION : 2026 LLBiz NCLT(GUA) 869
NCLT Mumbai Allows First Motion For Merger Of Siemens Rail Automation With Siemens Limited
The National Company Law Tribunal (NCLT) at Mumbai on 7 September allowed the first motion application seeking directions for the proposed merger of Siemens Rail Automation Private Limited with Siemens Limited under Sections 230 to 232 of the Companies Act, 2013.
Case Title : In the matter of Scheme of Amalgamation of Siemens Rail Automation Private Limited (Transferor Company No. 1) With Siemens Limited (Transferee Company)
Case Number : CA(CAA)/133/MB-IV/2026
CITATION : 2026 LLBiz NCLT (MUM) 872
Challenge To One Respondent's Maintainability Cannot Dismiss Entire Company Petition: NCLT Guwahati
The National Company Law Tribunal (NCLT) at Guwahati has held that a party cannot seek dismissal of an entire company petition when its pleadings only challenge the maintainability of proceedings against one particular respondent.
Case Title : Meghmallar Estates and Services Private Limited and Ors v. Aaryan Chilled Infra Private Limited
Case Number : IA(Comp Act)/12/GB/2023
CITATION : 2026 LLBiz NCLT(GUA) 875
Allahabad NCLT Sanctions Demerger Of KM Sugar Mills' Distillery Division Into KM Spirits
The Allahabad Bench of the National Company Law Tribunal (NCLT) on 19 August sanctioned a Scheme of Arrangement under Sections 230 to 232 of the Companies Act, 2013, approving the demerger of the Distillery Division of KM Sugar Mills Limited into its wholly owned subsidiary, KM Spirits and Allied Industries Limited.
Case Title : K M SUGAR MILLS LIMITED Vs KM SPIRITS AND ALLIED INDUSTRIES LIMITED Case Number : CP (CAA) NO.16/ALD/2026 IN CA (CAA) NO.05/ALD/2026
CITATION : 2026 LLBiz NCLT (ALL) 876
NCLT Ahmedabad Sanctions Share India-Silverleaf Capital Merger
The Ahmedabad bench of the National Company Law Tribunal (NCLT) has sanctioned the merger of Silverleaf Capital Services Pvt. Ltd. with listed Share India Securities Ltd.
The tribunal fixed October 1, 2023, as the appointed date despite flagging that the companies had not explained the delay in obtaining stock exchange observations.
Case Title : Silverleaf Capital Services Pvt. Ltd & Share India Securities Limited
Case Number : C.P.(CAA)/17(AHM)2026 in C.A.(CAA)/53(AHM)2025
CITATION : 2026 LLBiz NCLT (AHM) 877
NCLT Ahmedabad Sanctions First Motion For Inkia Inks–True Colors Amalgamation
The Ahmedabad Bench of the National Company Law Tribunal (NCLT) on 17 August sanctioned the first motion in the proposed amalgamation of Inkia Inks Private Limited with True Colors Limited, allowing the transferor company to dispense with certain meetings while directing meetings of equity shareholders and unsecured creditors of the transferee company.
Case Title : Inkia Inks Private Limited &True Colors Limited
Case Number : CA(CAA)30/(AHM)/2026
CITATION : 2026 LLBiz NCLT (AHM) 879
NCLT Chandigarh Bench Sanctions Merger Of Companies Behind Got Tea and Blue Tokai
The National Company Law Tribunal's Chandigarh bench has sanctioned the amalgamation of Thegot Hospitality Private Limited, which operates Got Tea, into Muhavra Enterprises Private Limited, the company behind Blue Tokai Coffee Roasters.
Case Title : THEGOT HOSPITALITY PRIVATE LIMITED Vs MUHAVRA ENTERPRISES PRIVATE LIMITED
Case Number : CP (CAA) No. 12/CHD/HRY/2026
CITATION : 2026 LLBiz NCLT(CHA) 886
The Ahmedabad bench of the National Company Law Tribunal (NCLT) has cleared the way for Landmark Cars (East) Private Limited to merge with its listed parent, Landmark Cars Limited, by dispensing with shareholder and creditor meetings for both companies.
Case Title : Landmark Cars (East) Private Limited & Landmark Cars Limited
Case Number : CA(CAA)/34(AHM)2026
CITATION : 2026 LLBiz NCLT (AHM) 890
The National Company Law Tribunal at Bengaluru recently held that mere existence of an arbitration clause in a Share Subscription Agreement does not make reference to arbitration mandatory.
It further observed that issues concerning corporate governance and reliefs under the Companies Act could not ordinarily be adjudicated through arbitration.
Case Title : Nowon Technologies Private Limited v. Mr. Tono Thomas
Case Number : CA No. 43 of 2024 in CP No. 88/BB/2021
CITATION : 2026 LLBiz NCLT(BEN) 896
NCLT New Delhi Sanctions Amalgamation Of Mawana Foods With Mawana Sugars
The New Delhi Bench of the National Company Law Tribunal (NCLT) on 3 September sanctioned the Scheme of Amalgamation between Mawana Foods Private Limited and Mawana Sugars Limited under the Companies Act, 2013.
Case Title : MAWANA FOODS PRIVATE LIMITED Vs MAWANA SUGARS LIMITED
Case Number : COMPANY PETITION NO. (CAA) 14 (ND)/2026
CITATION : 2026 LLBiz NCLT(DEL) 900
ROC Cannot Adjudicate Disputes Over Director Removal While Processing DIR-12: NCLT Ahmedabad
The Ahmedabad bench of the National Company Law Tribunal (NCLT) has ruled that the Registrar of Companies (RoC) can verify whether a director's removal complies with company law but cannot adjudicate disputes between parties while processing Form DIR-12.
Case Title : Satyanand Estate Private Limited Vs RoC Gujarat
Case Number : CP/39(AHM)2026
CITATION : 2026 LLBiz NCLT (AHM) 904
Mere Notice For Director's Removal Does Not Amount To Oppression: NCLT Ahmedabad
The Ahmedabad bench of the National Company Law Tribunal (NCLT) has held that a notice proposing a director's removal and an increase in a company's authorised share capital do not, by themselves, amount to oppression under the Companies Act, 2013.
Case Title : Nareshkumar Gondaliya Vs M.D Hygiene Pvt. Ltd & Ors
Case Number : CP/17(AHM)2026
CITATION : 2026 LLBiz NCLT (AHM) 907
NCLT Chennai Sanctions Amalgamation Of Augmento Labs With Saksoft Limited
The National Company Law Tribunal at Chennai has sanctioned the Scheme of Amalgamation between Augmento Labs Private Limited and Saksoft Limited, whose shares are listed on the National Stock Exchange and the Bombay Stock Exchange.
Case Title : Augmento Labs Private Limited v. Saksoft Limited
Case Number : CP(CAA)/93(CHE)/2025
CITATION : 2026 LLBiz NCLT(CHE) 927
Byju's Settles Rights Issue Dispute With Aakash Before NCLT Bengaluru
The National Company Law Tribunal (NCLT) at Bengaluru was on Wednesday informed that Think & Learn Private Limited, the parent company of Byju's, and Aakash Educational Services Limited have reached a settlement in their dispute over Aakash's rights issue.
Case Title : Think & Learn Pvt. Ltd. v. Aakash Educational Services Ltd
Case Number : C.P. No.135/BB/2025
NCLT Chennai Approves First Motion In Niyogin Fintech, Niyogin Finserv Composite Scheme
The National Company Law Tribunal at Chennai has allowed the first motion application filed by Niyogin Fintech Limited, Niyogin Finserv Limited and iServeU Technology Private Limited in relation to a proposed Composite Scheme of Arrangement.
Case Title : Niyogin Fintech Limited
Case Number : CA(CAA)/66(CHE)/2026
CITATION : 2026 LLBiz NCLT(CHE) 930
The Allahabad Bench of the National Company Law Tribunal (NCLT) on 15 September approved the First Motion application for the merger of Roto Energy Systems Ltd. with its parent company, Roto Pumps Ltd., under the Companies Act, 2013.
Case Title : ROTO ENERGY SYSTEMS LIMITED & ROTO PUMPS LIMITED
Case Number : CA (CAA) NO.15/ALD/2026
CITATION : 2026 LLBiz NCLT(ALL) 935
On 23 September, the National Company Law Tribunal (NCLT), Mumbai sanctioned a Composite Scheme of Arrangement involving the demerger of specified undertakings and amalgamation of Parle Products Private Limited with Parle Biscuits Private Limited, finding the scheme fair and reasonable and not contrary to law or public policy.
Case Title : PARLE PRODUCTS PRIVATE LIMITED
Case Number : C.P. (C.A.A)/98(MB)2026 IN C.A.(C.A.A)/105(MB)2026
CITATION : 2026 LLBiz NCLT (MUM) 936
The National Company Law Tribunal at Bengaluru has approved the reduction of share capital of India1 Payments Limited, involving cancellation of 45,16,129 equity shares held by IDBI Trusteeship Company Limited, trustee for India Advantage Fund S3 I, for an aggregate consideration of ₹69.99 crores.
Case Title : India1 Payments Limited v. Registrar of Companies
Case Number : CP No. 128/BB/2025
CITATION : 2026 LLBiz NCLT(BEN) 940
NCLT Mumbai Approves Vidarbha Industries Power Merger With Adani Power
The National Company Law Tribunal's Mumbai Bench has sanctioned the merger of Vidarbha Industries Power Limited with Adani Power Limited as part of a larger scheme under which 10 Adani Group companies are being amalgamated into Adani Power.
Case Title : IN THE MATTER OF Vidarbha Industries Power Limited
Case Number : C.P.(CAA)/71(MB)2026
CITATION : 2026 LLBiz NCLT (MUM) 942
NCLT Mumbai Vacates Property Attachment Of PNB Officers In Nirav Modi-Mehul Choksi Fraud Case
The National Company Law Tribunal at Mumbai has vacated the attachment of few properties in proceedings arising from the alleged fraud involving Nirav Modi, Mehul Choksi, and Gitanjali Gems.
Case Title : IN THE MATTER OF Prafull Sawant ... Applicant AND IN THE MATTER OF Becchu Tiwari
Case Number : Company Application No. 67 of 2021 IN CP (IB) 277 of 2018
CITATION : 2026 LLBiz NCLT (MUM) 943
NCLT Mumbai Allows First Motion Merger Of CIE Aluminium Casting With CIE Automotive India
The National Company Law Tribunal, Mumbai has allowed the first motion application for the merger by absorption of CIE Aluminium Casting India Ltd with CIE Automotive India Ltd, under Sections 230-232 of the Companies Act, 2013.
Case Title : In the matter of Scheme of Merger by Absorption between CIE Aluminium Casting India Limited (Transferor Company/Applicant Company-1) and CIE Automotive India Limited (Transferee Company/Applicant Company-2)
Case Number : CA(CAA)-115/MB/2026
CITATION : 2026 LLBiz NCLT (MUM) 946
NCLT Delhi Sanctions Merger Of Sesa Care With Dabur India
The New Delhi bench of the National Company Law Tribunal (NCLT) has sanctioned the amalgamation of Sesa Care Private Limited with Dabur India Limited, approving the merger of the ayurvedic personal care company with the listed FMCG major.
Case Title : SESA CARE PRIVATE LIMITED Vs DABUR INDIA LIMITED
Case Number : COMPANY PETITION NO. (CAA) - 33(ND)/2026
CITATION : 2026 LLBiz NCLT(DEL) 948
NCLT Allahabad Approves Magnum Ventures' Demerger Of Paper Business Into Magnum Paperz
The Allahabad bench of the National Company Law Tribunal (NCLT), has allowed the First Motion Application filed jointly by Magnum Ventures Limited (Demerged Company) and Magnum Paperz Limited (Resulting Company) under the Companies Act, 2013 proposing the demerger of the paper business from Magnum Ventures into Magnum Paperz.
Case Title : MAGNUM VENTURES LIMITED Vs MAGNUM PAPERZ LIMITED
Case Number : CA (CAA) NO.17/ALD/2026
CITATION : 2026 LLBiz NCLT(ALL) 957