IBC Weekly Round Up [23rd December-29th December 2024]

Update: 2024-12-30 12:25 GMT
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NOMINAL INDEX China Development Bank vs Doha Bank OPSC and others, 2024 LiveLaw (SC) 1029 Ram Kishor Arora, Suspended Director of Supertech Ltd. vs. Union Bank of India & Anr., Company Appeal (AT) (Insolvency) No. 406 of 2022 & Interlocutory Application No.6557 of 2024 Harpal Singh Chawla (Suspended Director of Spaze Towers Pvt. Ltd.) Versus Vivek Khanna &...

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NOMINAL INDEX

China Development Bank vs Doha Bank OPSC and others, 2024 LiveLaw (SC) 1029

Ram Kishor Arora, Suspended Director of Supertech Ltd. vs. Union Bank of India & Anr., Company Appeal (AT) (Insolvency) No. 406 of 2022 & Interlocutory Application No.6557 of 2024

Harpal Singh Chawla (Suspended Director of Spaze Towers Pvt. Ltd.) Versus Vivek Khanna & Ors., Interlocutory Application No.7853 of 2024 in Company Appeal (AT) (Insolvency) No. 2002 of 2024

Mr. Rakesh Kumar Jain vs. M/s ADTV Communications Private Limited, Company Appeal (AT) (Insolvency) No. 849 of 2023 & I.A. No. 2894, 2895 of 2023

Dinesh Kumar Versus Narendra Kumar Sharma & Ors., Company Appeal (AT) (Insolvency) No. 1422 of 2024

Mehul Patel (Member of Suspended Board of Anupam Port Cranes Corporation Ltd.) Vs. Nandish S. Vin & Anr, Company Appeal (AT) (Insolvency) No.2191 of 2024

Ghaziabad Development Authority vs. Competition Commission of India, Competition Appeal (AT) No. 26 of 2018

Varun Gupta vs. ISINOX Pvt. Ltd. Through the IRP Mr. Manishkumar R. Patel & Ors., Comp. App. (AT) (Ins) No. 430 of 2023 & I.A. No. 1429, 1430, 1431 of 2023 & 2005 of 2024

Vadilal Industries Ltd. vs. Fanendra Munot & Ors., Company Appeal (AT) (Ins.) No. 748 of 2023

Vidyadhar Sarfare & Anr Versus CS Anagha Anasingharaju & Ors., Company Appeal (AT) (Insolvency) No.1733 of 2024

M/S ALLIED HI-TECH INDUSTRIES PRIVATE LIMITED VS. KARVY DATA MANAGEMENT SERVICES LIMITED, I.A. (IBC) (PLAN) NO.24 OF 2024 IN CP (IB) No. 25/7/HDB/2022

: M/s. METRO TYRES LIMITED VERSUS M/s. HERO ELECTRIC VEHICLES PVT. LTD, C.P. (IB) –397(ND)/2024

SUPREME COURT

IBC | Financial Creditor Can Submit Claim Even If There Is No Default Of Debt : Supreme Court

Case Title : China Development Bank vs Doha Bank OPSC and others

Citation : 2024 LiveLaw (SC) 1029

The Supreme Court has observed a default is not necessary for a debt to become a financial debt under the Insolvency and Bankruptcy Code, 2016.

A bench comprising Justice Abhay S Oka and Justice Augustine George Masih held that under Section 5(7) of the IBC, any person to whom financial debt is owed becomes a Financial Creditor even if there is no default in payment of debt. "Therefore, for submitting the claim by a Financial Creditor, there is no requirement of actual default," the Court held.

NCLAT

NBCC To Lead Completion Of Supertech's Stalled Projects, Securing Homebuyers' Rights

Case Title: Ram Kishor Arora, Suspended Director of Supertech Ltd. vs. Union Bank of India & Anr.

Case Number: Company Appeal (AT) (Insolvency) No. 406 of 2022 & Interlocutory Application No.6557 of 2024

In a landmark judgment, the National Company Law Appellate Tribunal (NCLAT) Delhi bench comprising Justice Ashok Bhushan (Chairperson) and Barun Mitra (Technical Member) has approved NBCC (India) Ltd.'s proposal to complete 16 incomplete projects of Supertech Limited. NBCC will act as the Project Management Consultant to ensure timely and quality completion of these projects. The judgment advocates for transparency and accountability in the real estate industry and protection of the rights of homebuyers, lenders, and public funds.

No Claim Survives When Unit Holder Is Handed Over Possession And Conveyance Deed Has Been Executed: NCLAT

Case Title: Harpal Singh Chawla (Suspended Director of Spaze Towers Pvt. Ltd.) Versus Vivek Khanna & Ors.

Case Number: Interlocutory Application No.7853 of 2024 in Company Appeal (AT) (Insolvency) No. 2002 of 2024

The NCLAT New Delhi bench of Mr. Justice Ashok Bhushan (Chairperson), Mr. Barun Mitra (Technical Member) and Mr. Arun Baroka (Technical Member) has held that when a unit holder is handed over possession and a Conveyance Deed has also been executed, no claim survives of such unit holders. Whether a claim filed by a Financial Creditor in a class, deserves admission, is a question, which need to be first looked into by the RP as per the statutory regulations governing the collation and verification of the claim.

Decree Holder Is “Financial Creditor” Under IBC, Limitation For Filing Section 7 Petition Is Extendable On Acknowledgment Of Debt: NCLAT

Case Title: Mr. Rakesh Kumar Jain vs. M/s ADTV Communications Private Limited

Case Number: Company Appeal (AT) (Insolvency) No. 849 of 2023 & I.A. No. 2894, 2895 of 2023

The National Company Law Appellate Tribunal (NCLAT) New Delhi bench comprising Justice Yogesh Khanna (Judicial member) and Arun Baroka (Technical member) has held that a decree holder falls within the definition of "Financial Creditor" under Section 5(7) and Section 5(8) of the Insolvency and Bankruptcy Code (IBC) if the decree is based on a financial debt. The Tribunal observed that the cause of action for initiating proceedings under Section 7 of the IBC arises when the debt is acknowledged by the debtor. The Tribunal noted that the Petition filed by the Appellant was within the limitation period as the Respondent had acknowledged the debt, extending the limitation period under Section 18 of the Limitation Act, 1963. It initiated the Corporate Insolvency Resolution Process (CIRP) against the Respondent.
Status Report Submitted In Criminal Proceeding Can Have No Bearing While Deciding Application U/S 7 Of IBC: NCLAT

Case Title: Dinesh Kumar Versus Narendra Kumar Sharma & Ors.

Case Number: Company Appeal (AT) (Insolvency) No. 1422 of 2024

The NCLAT New Delhi bench of Justice Ashok Bhushan (Judicial Member) and Mr. Arun Baroka (Technical Member) has held that Status Report submitted in a criminal proceeding regarding allegations of fraud and forgery can have no bearing while deciding Section 7 Application. The said Status Report is not an evidence on which it can be pronounced that threshold of 100 allottees was not complete in filing of Section 7 Application.
Application U/S 12A Of IBC Can Be Withdrawn By Resolution Professional Before It Is Heard Or Allowed: NCLAT

Case Title: Mehul Patel (Member of Suspended Board of Anupam Port Cranes Corporation Ltd.) Vs. Nandish S. Vin & Anr

Case Number: Company Appeal (AT) (Insolvency) No.2191 of 2024

The NCLAT New Delhi bench of Justice Ashok Bhushan (Judicial Member), Barun Mitra (Technical Member) and Arun Baroka (Technical Member) has held that CIRP withdrawal application can be withdrawn by Resolution Professional before the application is heard and allowed.

Ghaziabad Development Authority Abused Dominant Position By Imposing Unfair Terms On Allottees Of EWS Housing Scheme, NCLAT Imposes 5% Penalty

Case Title: Ghaziabad Development Authority vs. Competition Commission of India

Case Number: Competition Appeal (AT) No. 26 of 2018

Ghaziabad Development Authority (GDA) filed an appeal, challenging the Competition Commission of India's (CCI) order wherein the CCI found that GDA had abused its dominant position in the market for the provision of services related to the development and sale of low-cost residential flats for Economically Weaker Sections (EWS) under the Pratap Vihar Residential Housing Scheme. GDA was found to have unilaterally increased the prices of flats and imposed arbitrary and unfair terms on allottees, violating Section 4(2)(a)(i) of the Competition Act. The CCI imposed a penalty of 5% of GDA's average turnover for the last three years in connection with the relevant market.

NCLAT Sets Aside Admission Of S.7 Application Upon Finding Transaction Was In Nature Of 'Operational Debt'

Case Title: Varun Gupta vs. ISINOX Pvt. Ltd. Through the IRP Mr. Manishkumar R. Patel & Ors.

Case Number: Comp. App. (AT) (Ins) No. 430 of 2023 & I.A. No. 1429, 1430, 1431 of 2023 & 2005 of 2024

The NCLAT New Delhi bench of Justice Rakesh Kumar Jain (Judicial Member), Mr. Barun Mitra (Technical Member) and Mr. Indevar Pandey (Technical Member) has held that the application under Section 7 of the Insolvency and Bankruptcy Code, 2016, was not maintainable as the transaction in question constituted an 'operational debt' and was not covered under Section 5(8)(e) but was governed by Section 5(20) and Section 21(5) of the Code. The Tribunal allowed the appeal against the admission of petition under section 7 and relegated the Respondents to pursue their remedy under Section 9 of the Code.

Once CoC Approves Resolution Plan Then No Claim Is To Be Entertained: NCLAT

Case Title: Vadilal Industries Ltd. vs. Fanendra Munot & Ors.

Case Number: Company Appeal (AT) (Ins.) No. 748 of 2023

The NCLAT New Delhi bench of Justice Rakesh Kumar Jain (Judicial Member), Mr. Barun Mitra (Technical Member) and Mr. Indevar Pandey (Technical Member) have reiterated that once the Committee of Creditor (CoC) has approved the resolution plan, then no claim is to be entertained.

CIRP Withdrawal Cannot Be Allowed Unless Application Is Filed By Applicant Who Initiates Section 7 Application: NCLAT

Case Title: Vidyadhar Sarfare & Anr Versus CS Anagha Anasingharaju & Ors.

Case Number: Company Appeal (AT) (Insolvency) No.1733 of 2024

The NCLAT New Delhi bench of Justice Ashok Bhushan (Judicial Member) and Barun Mitra (Technical Member) has held that CIRP cannot be withdrawn under section 12A read with Regulation 30A unless application for withdrawal is filed by the applicant who initiated the CIRP.
NCLT

NCLT Hyderabad Approves Resolution Plan For Karvy Data Management Services Limited

Case Title: M/S ALLIED HI-TECH INDUSTRIES PRIVATE LIMITED VS. KARVY DATA MANAGEMENT SERVICES LIMITED

Case Number: I.A. (IBC) (PLAN) NO.24 OF 2024 IN CP (IB) No. 25/7/HDB/2022

The National Company Law Tribunal (NCLT) Hyderabad bench of Dr. N. Venkata Ramakrishna Badarinath (Judicial Member) and Shri Charan Singh (Technical Member) has approved the Resolution Plan of Karvy Data Management Services Ltd (KDMSL). It was approved on December 13, 2024. KDMSL, incorporated on 21.04.2008, is a prominent provider of integrated business and knowledge process services. Its clients include UIDAI (Aadhaar Seva Kendras), SEBI (KRA Services) and Protean E-Gov Technologies Limited. Due to operational inefficiencies, market downturns, and external economic reasons, the company experienced financial difficulties, which led to the initiation of Corporate Insolvency Resolution Process (CIRP).

No Provision In IBC To Issue Multiple Demand Notices Before Filing Petition U/S 9 Of IBC: NCLT New Delhi

Case Title: M/s. METRO TYRES LIMITED VERSUS M/s. HERO ELECTRIC VEHICLES PVT. LTD

Case Number: C.P. (IB) –397(ND)/2024

The NCLT New Delhi bench of Justice Shri Bachu Venkat Balaram Das (Judicial Member) and Shri Atul Chaturvedi (Technical Member) has held that there is no such provision in the IBC, 2016 and in the Regulation made thereunder that allows the Operational Creditor to issue multiple demand notices to the Corporate Debtor
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