NCLT Hyderabad Orders Consolidated CIRPs Of Panduranga Energy Systems, GMP Infrastructure

The National Company Law Tribunal (NCLT) at Hyderabad has ordered substantive consolidation of the insolvency resolution processes of Panduranga Energy Systems Private Limited (PESPL) and GMP Infrastructure Private Limited (GMP), finding that their interconnected assets, financial arrangements and business operations make separate resolution impracticable.

A bench of Judicial Member Rajeev Bhardwaj and Technical Member Sanjay Puri held that the companies share common control and ownership, interlinked financial arrangements, common financial creditors and security arrangements, satisfying the parameters for substantive consolidation.

"In the present case, there exists common control and ownership, interlinked financial arrangements, common financial creditors, common security arrangements, interdependence of assets and business operations, and the impracticability of separate resolution, thereby satisfying the relevant parameters for considering substantive consolidation.", the Tribunal observed.

The case arose when Union Bank of India initiated insolvency proceeding against PESPL, the principal borrower and GMP, its corporate guarantor over the same financial facilities. Both petitions were admitted on February 5, 2026. Their Committees of Creditors comprised Union Bank of India, Indian Bank and Canara Bank, with identical admitted claims of ₹2,131.68 crore in each CIRP.

PESPL's 116 MW gas based power plant at Annadevarapeta, Andhra Pradesh, is situated on land owned by GMP and leased under a deed dated April 29, 2010. The land is also mortgaged to secure PESPL's financial facilities.

The Tribunal observed that resolving PESPL separately, without the underlying land belonging to GMP, could affect access to the land and common infrastructure, reducing the realisable value of the plant and machinery. Similarly, resolving GMP independently without considering PESPL's machinery situated on its land could prevent optimal value maximisation.

On the issue of common financial arrangements, the Tribunal noted that the same financial debt of ₹2,131.68 crore was admitted in both CIRPs, with identical financial creditors and a common Resolution Professional.

The land belonging to GMP also formed part of the security for PESPL's financial facilities, alongside GMP's corporate guarantee.

"Further, the financial creditors in both CIRPs are identical, and the same financial debt of Rs. 2,131.68 crore stands admitted in both CIRPs. The common Resolution Professional and the resolutions passed by the respective CoCs further support the coordinated conduct of the two CIRPs.", the Tribunal said.

The Bench also took note of the CoC of PESPL's seventh meeting held on August 20, 2026, which concluded that separate resolution plans might not maximise value. Its resolution authorising the consolidation application was approved with 100% voting share through e voting on September 1, 2026. GMP's CoC passed a similar resolution on September 15, 2026.

Accordingly, the Tribunal directed that both CIRPs be treated as a single process, with assets and liabilities forming a common pool, a combined CoC and the common Resolution Professional continuing.

It also directed issuance of a fresh Form G, if required and transfer of all pending claims, applications and proceedings to the consolidated CIRP.

For the Applicant: Advocate GP Yash Vardhan

Venkat Narsinga Rao Kalvakota, Resolution Professional