LiveLawBiz IBC Weekly Digest: June 1 - June 6, 2026
Kirit Singhania
8 Jun 2026 9:37 AM IST
SUPREME COURT
Case Title : CA RAMCHANDRA DALLARAM CHOUDHARY Versus ADANI INFRASTRUCTURE AND DEVELOPERS PRIVATE LIMITED
Case Number : DIARY NO. 5988 OF 2026
The Supreme Court on Monday declined to interfere with a National Company Law Appellate Tribunal (NCLAT) order directing Adani Infrastructure & Developers Pvt Ltd to pay 12% interest on delayed payment of ₹255 crore. The amount formed part of the consideration for its ₹325-crore purchase of a land parcel belonging to Anil Ltd, which is under liquidation. A bench of Justices Dipankar Datta and Satish Chandra Sharma dismissed an appeal filed by the liquidator. The liquidator had challenged the NCLAT's decision to waive interest for a portion of the delay period.
Case Title : COSMIC CRF LIMITED VERSUS MYOTIC TRADING PRIVATE LIMITED & ORS. Case Number : Civil Appeal Nos.4266-4267/2026
CITATION : 2026 LLBiz SC 215
The Supreme Court has recently held that once a company has been resolved under an approved insolvency resolution plan and all remaining dues stand extinguished, those dues cannot be "resurrected" to assess the eligibility of a prospective resolution applicant a year later. It set aside orders that had declared Cosmic CRF Ltd ineligible to participate in the corporate insolvency resolution process of Amzen Transportation Industries Pvt. Ltd.
Supreme Court Upholds Admission of Insolvency Plea Filed by Ingram Micro Against Bathla Teletech
Case Title : BATHLA TELETECH PRIVATE LIMITED vs INGRAM MICRO INDIA PRIVATE LIMITED
Case Number : Civil Appeal No(s). 8188/2026
CITATION : 2026 LLBiz SC 219
The Supreme Court has refused to interfere with an NCLAT ruling that Bathla Teletech Pvt Ltd's claims relating to unsold iPhone 8 inventory and backend discounts did not constitute a genuine pre-existing dispute capable of defeating an insolvency application. The order leaves intact insolvency proceedings against the electronics reseller at the instance of Ingram Micro India Pvt Ltd. A Bench of Justices Dipankar Datta and Satish Chandra Sharma dismissed an appeal filed by Bathla Teletech, holding that no substantial question of law arose from the NCLAT's judgment.
Case Title : THRANI INDUSTRIES LTD VERSUS KNK MANAGEMENT
Case Number : Diary No(s). 61278/2025
CITATION : 2026 LLBiz SC 220
The Supreme Court has refused to entertain an appeal by Thrani Industries Ltd against insolvency proceedings initiated against it, holding that the company's explanation for a 166-day delay in refiling the case was nothing more than a "lame excuse". A Bench of Justices Dipankar Datta and Satish Chandra Sharma dismissed the appeal after finding that Thrani Industries had failed to show any sufficient cause for the prolonged delay.
HIGH COURT
IBC Resolution Plan Acceptance Is “Settlement” Under Section 16 Court Fees Act: Delhi High Court
Case Title : SAINIK INDUSTRIES PVT. LTD Vs INDIAN SUGAR MANUFACTURING COMPANY LIMITED
Case Number : CS(COMM) 474/2019
CITATION : 2026 LLBiz HC (DEL) 572
On 1 June, the Delhi High Court held that acceptance of claims under a resolution plan in insolvency proceedings amounts to a “settlement” within the meaning of Section 16 of the Court Fees Act, 1870, thereby entitling a plaintiff to refund of court fee upon withdrawal of the suit. Justice Subramonium Prasad allowed Sainik Industries Pvt. Ltd. to withdraw its recovery suit against Indian Sugar Manufacturing Company Ltd. and directed refund of the entire court fee.
NCLAT
NCLAT Delhi Rules Unregistered Development Agreement Cannot Defeat CIRP Rights Over Ananta Residency
Case Title : Phoenix ARC Pvt. Ltd Vs Halwasiya Developments Pvt. Ltd. & Ors
Case Number : Company Appeal (AT) (Insolvency) 164-166/2025, 266-268/2025, 295/2025 & 365/2025
CITATION : 2026 LLBiz NCLAT 248
he New Delhi Bench of the National Company Law Appellate Tribunal on 25 May partly allowed a batch of appeals concerning the Ananta Residency project, holding that Halwasiya Developments Pvt. Ltd. could not claim ownership or exclusive rights under an unregistered Development Agreement executed in 2018. Chairperson Justice Ashok Bhushan and Technical Member Barun Mitra noted that the project continued to form part of the Corporate Insolvency Resolution Process (CIRP) despite the 2014 mortgage and initiation of insolvency proceedings against the Corporate Debtor.
NCLAT New Delhi Orders Fresh Auction In MBSL Case, Holds JFC Finance Excluded Over BAANKNET Glitch
Case Title : JFC FINANCE (INDIA) LTD. Vs ARVIND GARG & Ors
Case Number : Company Appeal (AT) (Insolvency) 1820/2025
CITATION : 2026 LLBiz NCLAT 249
The New Delhi National Company Law Appellate Tribunal (NCLAT) on 29 May allowed the appeal filed by JFC Finance (India) Ltd., holding that the bidder was wrongfully excluded from the e-auction process due to a possible technical glitch on the BAANKNET platform and directing a fresh auction with a reserve price of Rs 54 crore.
NCLT
Case Title : SREI Equipment Finance Limited v. Kitply Industries Limited
Case Number : CP(IB)/8/GB/2024
CITATION : 2026 LLBiz NCLT(GUA) 527
The National Company Law Tribunal (NCLT) at Guwahati has held that insolvency proceedings cannot be admitted mechanically where serious disputes concerning the genuineness and enforceability of the underlying debt are already pending consideration before another forum. A bench of Judicial Member Rammurti Kushawaha and Technical Member Yogendra Kumar Singh observed, “Where the creditor itself alleges in separate proceedings that the transaction is fraudulent and constitutes wrongful trading, this Tribunal cannot mechanically proceed on the assumption that a clear and undisputed 'financial debt' exists. The issue is not merely about computation of dues but concerns the very substratum and legitimacy of the transaction itself.”
NCLT Delhi Rejects Jiostar's Insolvency Plea Against Legends League Cricket Promoter
Case Title : Jiostar India Pvt. Ltd. Vs Absolute Legends Sports Private Limited
Case Number : C.P. IB/667/ND/2025
CITATION : 2026 LLBiz NCLT(DEL) 529
The Delhi bench of the National Company Law Tribunal (NCLT) has recently dismissed an insolvency plea filed by Jiostar India Pvt. Ltd. against Absolute Legends Sports Pvt. Ltd., the company behind the Legends League Cricket Masters T20 tournament. The tribunal held that Jiostar failed to establish that its claim for unpaid commentary-production charges and reimbursement of Ministry of Information and Broadcasting (MIB) fees under agreements relating to the broadcast rights of the Legends League Cricket tournament qualified as an operational debt.
Case Title : Ashok Arora Vs Mothers Pride Education Personna Pvt. Ltd & Presidium Educational Institution Pvt. Ltd.
Case Number : I.A. NO. 6318 OF 2025 IN C.P. IB 559 (ND) OF 2021 & I.A. NO. 6314 OF 2025 IN C.P. IB 638 (ND) OF 2021
CITATION : 2026 LLBiz NCLT(DEL) 530
On 1 June, the New Delhi Bench of the National Company Law Tribunal (NCLT) ended the insolvency proceedings against Presidium Educational Institution Pvt. Ltd. and Mothers Pride Education Personna Pvt. Ltd., after finding that the process had gone beyond the 330-day legal limit, suffered from irregularities, and did not result in any resolution plan. Judicial Member Manni Sankariah Shanmuga Sundaram and Technical Member Atul Chaturvedi disposed of the CIRPs and recalled the admission orders and withdrew the moratorium under Section 14 of the Insolvency and Bankruptcy Code, 2016
Case Title : UCO Bank v. Mrs. Mallika Barooah
Case Number : CP(IB)/13/GB/2025
CITATION : 2026 LLBiz NCLT(GUA) 531
The National Company Law Tribunal (NCLT) at Guwahati has rejected UCO Bank's insolvency application seeking initiation of proceedings against Mallika Barooah in relation to dues claimed from Berial Engineers Private Limited. The tribunal held that the bank failed to establish invocation of the guarantee and that the application was barred by limitation. A bench of Judicial Member Rammurti Kushawaha and Technical Member Yogendra Kumar Singh passed the order while dealing with the bank's application against Barooah. The bank claimed that she was a personal guarantor to credit facilities extended to the company.
Redirecting RP To MCA Website Does Not Constitute Cooperation Under IBC: NCLT Indore
Case Title : Teena Saraswat Pandey Vs Aditya Bhatnagar
Case Number : IA/224(MP)2025 in CP(IB)/17(MP)2024
CITATION : 2026 LLBiz NCLT(IND) 533
Merely directing a Resolution Professional (RP) to obtain information from public portals such as the MCA website and responding with "refer MCA website" or "not applicable" does not amount to cooperation during the insolvency resolution process, the National Company Law Tribunal (NCLT) at Indore has reiterated while directing the suspended management of Xyron Technologies Limited to furnish records sought by the RP.
NCLT Hyderabad Flags Nearly Ten-Fold Increase In Admitted Claim In CIRP, Orders Fresh Verification
Case Title : Frontline Enterprises Limited vs. Global Insolvency Professionals Private Limited and Anr
Case Number : CP (IB) No. IA (IBC) No. 1580 of 2025 In CP (IB) No. 217/7/HDB/ 2024
CITATION : 2026 LLBiz NCLT(HYD) 534
The National Company Law Tribunal (NCLT) at Hyderabad has directed a fresh verification of a financial creditor's claim in the corporate insolvency resolution process of Sri Nagakrishna Chemicals Ltd. after noting a nearly ten-fold increase in the admitted claim amount. The tribunal noted that the amount reflected in the creditor's application was about ₹7.95 crore, while the amount admitted during the CIRP stood at ₹73.98 crore.
Insolvency Plea Must Be Based On Fresh Default After Loan Account Regularisation: NCLT Mumbai
Case Title : IIFL Home Finance Limited vs Bombay ISLE Developers Private Limited
Case Number : CP (IB) No. 352/(MB)/2024
CITATION : 2026 LLBiz NCLT (MUM) 537
The Mumbai bench of the National Company Law Tribunal (NCLT) has held that a financial creditor cannot base an insolvency petition on a historical default that ceased to exist after the loan account was regularised, and must instead rely on a fresh default specifically pleaded in the application. Judicial Member Sushil Mahadeorao Kochey and Technical Member Prabhat Kumar observed: “If the Corporate Debtor commits another default after the account has been regularised, a fresh Default occurs, and an application may lie basis such default, but such date of default has to be expressly pleaded by the applicant in the application. The Financial Creditor must file the Section 7 Petition using this new date of default, not the historical one. A Financial Creditor cannot base its Section 7 Petition on a historical Default date that no longer exists. Doing so makes the Petition technically flawed and subject to dismissal by this Adjudicating Authority.”
Case Title : In the matter of Smt. Madhubala R Jain, Personal Guarantor to M/s. Kankria Agro Limited
Case Number : C.P. (IB) NO. 203/MB/2026
CITATION : 2026 LLBiz NCLT (MUM) 539
The National Company Law Tribunal (NCLT) at Mumbai has admitted an insolvency resolution application filed by a personal guarantor. It held that the pendency of recovery proceedings under the SARFAESI Act, by itself, cannot render such an application non-maintainable. A coram of Judicial Member Sushil Mahadeorao Kochey and Technical Member Prabhat Kumar observed: “In view of the overriding effect accorded to the Insolvency and Bankruptcy Code, 2016 under Section 238, pendency of recovery proceedings under the SARFAESI Act cannot, by itself, render the present application non-maintainable. In the absence of material demonstrating mala fides or abuse of process, the present proceedings cannot be rejected solely on the ground that recovery proceedings had already been initiated by the Financial Creditor. Though the filing of the present application immediately prior to the scheduled e-auction may raise suspicion, the same, in the absence of any further material, cannot by itself constitute a ground for rejection of the application.”
Case Title : Suman Kumar Verma Resolution Professional vs Countertops and Cabinets (India) Private Limited & Ors
Case Number : IA (I.B.C)/5092/2025 IN CP (IB) 903/2019
CITATION : 2026 LLBiz NCLT (MUM) 541
The National Company Law Tribunal (NCLT) in Mumbai has recently held that a tenant's continued occupation of a corporate debtor's property after expiry of its arrangement cannot defeat the objectives of the corporate insolvency resolution process (CIRP) or obstruct implementation of an approved resolution plan. The tribunal directed Countertops and Cabinets (India) Pvt Ltd to hand over possession of a Jaipur property owned by Krystal Stone Exports Ltd within 15 days.
NCLT Ahmedabad Admits Insolvency Plea Against Osia Hyper Retail's Personal Guarantor
Case Title : Unity Small Finance Bank Limited Vs Kavita Dhirendra Chopra
Case Number : C.P.(IB)/361(AHM)2025 & IA/365(AHM)2026 in C.P.(1B)/361(AHM)2025
CITATION : 2026 LLBiz NCLT (AHM) 543
The Ahmedabad bench of the National Company Law Tribunal (NCLT) has admitted an application filed by Unity Small Finance Bank Limited and initiated insolvency resolution proceedings against Kavita Dhirendra Chopra, the personal guarantor of Osia Hyper Retail Limited. The application was filed in relation to an alleged default of Rs. 10,03,58,635.
NCLT Mumbai Rejects Personal Guarantor's Insolvency Plea, Says It Was Filed To Scuttle Auction Sale
Case Title : In the matter of MRS. VANDANA RAVINDRA CHAUDHARI(Personal Guarantor of Heera Ind Trading Pvt. Ltd.)
Case Number : C.P. (IB) NO. 794/MB/2025
CITATION : 2026 LLBiz NCLT (MUM) 544
The National Company Law Tribunal (NCLT) in Mumbai has rejected a personal insolvency plea filed by a personal guarantor to Heera Group companies. It observed that the application was moved after the auction of a mortgaged property and was intended to scuttle the concluded auction process initiated by Union Bank of India. A Bench of Judicial Member Sushil Mahadeorao Kochey and Technical Member Prabhat Kumar dismissed the plea filed by Vandana Ravindra Chaudhari. She had furnished personal guarantees for credit facilities extended by Union Bank of India to Heera Ind Trading Pvt Ltd, Heera Hospitality Pvt Ltd and Pratham Heera Sales Pvt Ltd.
Housing Society Cannot Recover Admitted Insolvency Dues From Auction Buyers: NCLT Mumbai
Case Title : Anil Patel & Ors. Versus Panchratna Co-operative Housing Society and Anr.
Case Number : IA 1195/2026
CITATION : 2026 LLBiz NCLT (MUM) 545
The National Company Law Tribunal (NCLT) at Mumbai has held that a housing society which has lodged and secured admission of its claim in a corporate debtor's insolvency proceedings cannot seek to recover the same dues directly from purchasers of the debtor's property sold during liquidation. A Bench of Judicial Member Sushil Mahadeorao Kochey and Technical Member Prabhat Kumar passed the ruling while allowing an application filed by auction purchasers Anil Patel, Kiran Patel and Madhav Patel in relation to a flat purchased by them in the liquidation of C. Mahendra Export Ltd.
IBBI
IBBI Introduces Framework For Termination Of Voluntary Liquidation Proceedings
The Insolvency and Bankruptcy Board of India (IBBI) has put in place a formal mechanism for ending voluntary liquidation proceedings before a company is dissolved. The latest changes also tighten the claims process by requiring stakeholders to update claims that have been partly or fully satisfied and by obligating liquidators to explain why any claim has been rejected. The changes have been introduced through the Insolvency and Bankruptcy Board of India (Voluntary Liquidation Process) (Second Amendment) Regulations, 2026, which came into force on June 1.
IBBI Introduces Wider Asset Disclosure Requirements For Personal Guarantors
The Insolvency and Bankruptcy Board of India (IBBI) has amended the insolvency resolution and bankruptcy frameworks governing the personal guarantors to corporate debtors. The changes mandate a comprehensive asset disclosure and lay down a mechanism to facilitate asset transfers in related corporate insolvency proceedings. The changes came into force from June 1, 2026, through the Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Personal Guarantors to Corporate Debtors) (Amendment) Regulations, 2026, and the IBBI (Bankruptcy Process for Personal Guarantors to Corporate Debtors) (Second Amendment) Regulations, 2026.