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Official Legislative Archive

The Insolvency and Bankruptcy Code (Amendment) Bill, 2025

SECTION Section 1

Untitled Section

1
INSOLVENCY AND BANKRUPTCY NEWS
CONTENTS
FROM CHAIRPERSON’S DESK ............................................................................................................................................................... 2
A.IBBI Updates ................................................................................................................. ................................................................ 3
A.1 Key Events .................................................................................................................. ......................................................... 3
A.2 Employee Trainings and Workshops ............................................................................................ ....................................... 3
B.Legal and Regulatory Framework ............................................................................................... ................................................ 3
B.1 Regulations .......................................................................................................................................................................... 3
B.2 Circulars ............................................................................................................................................................................... 4
B.3 Guidelines ............................................................................................................................................................................ 4
B.4 Invitation of public comments ............................................................................................... ................................................ 4
C.Corporate Processes .......................................................................................................... .......................................................... 4
C.1 Overview ............................................................................................................................................................................... 4
C.2 Ratio of Resolution and Liquidation orders .................................................................................. ........................................ 6
C.3 Stakeholder-wise initiation of CIRP ......................................................................................... ............................................. 6
C.4 Timelines .............................................................................................................................................................................. 6
C.4.1 For Concluded Processes ................................................................................................... .................................... 6
C.4.2 For Ongoing CIRPs ......................................................................................................... ........................................ 7
C.5 Resolution Plans ............................................................................................................ ...................................................... 7
C.5.1 Overall outcomes .......................................................................................................... ........................................... 7
C.5.2 Resolution of Large Cases (Admitted Claims > Rs. 1000 crore) .............................................................. .............. 9
C.5.3 Resolution of FiSPs ....................................................................................................... .......................................... 9
C.6 Withdrawals under Section 12A ............................................................................................... .......................................... 10
C.7 Liquidation .......................................................................................................................................................................... 10
C.7.1 Overall outcomes .......................................................................................................... ......................................... 10
C.7.2 Reasons for liquidation ................................................................................................... ....................................... 12
C.7.3 Claims in liquidation process ............................................................................................. .................................... 12
C.7.4 Sale as Going Concern ..................................................................................................... .................................... 12
C.8 Voluntary Liquidation ....................................................................................................... ................................................... 12
C.8.1 Overview ................................................................................................................................................................ 12
C.8.2 Dissolution orders in voluntary liquidation ............................................................................... .............................. 13
C.9 Corporate Liquidation Accounts .............................................................................................. ........................................... 15
C.10 Pre-Packaged Insolvency Resolution Process ................................................................................. ................................. 15
C.11 Avoidance Transactions .................................................................................................... ................................................. 15
D.Individual Processes ......................................................................................................... ......................................................... 16
D.1 Insolvency Resolution Process ............................................................................................... ........................................... 16
D.2 Bankruptcy Process .......................................................................................................... ................................................. 16
E.Service Providers ............................................................................................................ ............................................................ 16
E.1 Insolvency Professionals .................................................................................................... ................................................ 16
E.2 Replacement of IRP with RP .................................................................................................. ............................................ 17
E.3 Insolvency Professional Entities............................................................................................ ............................................. 18
E.4 Insolvency Professional Agencies ............................................................................................ .......................................... 18
E.5 Information Utility......................................................................................................... ....................................................... 19
E.6 Registered Valuer Organisations ............................................................................................. .......................................... 19
E.7 Complaints and Grievances ................................................................................................... ............................................ 20
E.8 Examinations ...................................................................................................................................................................... 20
E.8.1 Limited Insolvency Examination ............................................................................................ ................................ 20
E.8.2 Valuation Examinations .................................................................................................... ..................................... 21
E.9 Disciplinary Orders ......................................................................................................... .................................................... 21
F.Orders ....................................................................................................................... ........................................................ 21
F.1 Supreme Court ............................................................................................................... .................................................... 21
F.2 National Company Law Appellate Tribunal ..................................................................................... ................................... 23
F.3 National Company Law Tribunal ............................................................................................... ......................................... 25
G.Building Ecosystem ........................................................................................................... ......................................................... 25
G.1 IP Workshops ................................................................................................................ ..................................................... 25
G.2 Advocacy and Awareness ...................................................................................................... ............................................ 26
G.3 Other Programmes ............................................................................................................ ................................................. 26
List of Abbreviations ............................................................................................................................................................................. 27
INSOLVENCY AND BANKRUPTCY NEWS
2
From Chairperson’s Desk
The Information Memorandum (IM) is a key document prepared by
the Resolution Professional (RP) that contains complete and
detailed information about the financial, legal, and operational
position of the corporate debtor (CD). The main purpose of the IM
is to provide prospective resolution applicants (PRAs) with the
information they need to assess the viability of the CD and submit
well-informed and competitive resolution plans.
Just as an IPO prospectus reveals a company’s fundamentals for
public investment, the IM presents a transparent and data-backed
profile of a distressed corporate debtor - outlining assets, operations,
legal risks, financial performance, and the path to revival.
For PRAs, the IM is not just a document - it’s a deal originator, a
risk-mapper, and a value guide, rolled into one. Whether a strategic
buyer seeking operational synergies or a financial investor exploring
turnaround potential, the IM equips prospective bidders with the
insights needed to assess viability, structure competitive bids, and
chart a roadmap for business revival. By bridging information
asymmetry, it serves as the foundation for market-driven resolution
— where transparency fosters trust, and informed bidding unlocks
value from distress.
A well-drafted IM also enables the Committee of Creditors (CoC)
members to understand the CD’s financial and business position
clearly, helping them make timely and informed decisions. Its
completeness and accuracy can have a major impact on the
outcome of the resolution process.
Benefits of the Information Memorandum (IM)
/g122Informed Decision-Making : The IM provides prospective
resolution applicants (PRAs) and the CoC with comprehensive
financial, legal, and operational data. This allows them to
evaluate the viability of the corporate debtor (CD) and make
informed decisions regarding resolution plans.
/g122Transparency and Fairness : By disclosing all material
information, including related party transactions, litigations, and
tax attributes, the IM promotes transparency and ensures a
level playing field among all resolution applicants.
/g122Efficient Price Discovery : Detailed disclosures such as
business performance,intangible assets and tax losses, of the
corporate debtor enable better assessment of the CD’s worth.
This improves the accuracy of price discovery and the
competitiveness of bids.
/g122Maximization of Value : By enabling resolution applicants to
factor in synergies, potential tax benefits, and going concern
value, the IM supports the submission of plans that aim to
maximize value for stakeholders.
/g122Risk Identification and Mitigation : Inclusion of information
on pending litigation, and contingent liabilities help the
applicants and creditors to identify legal or financial risks
associated with the CD and address them in their plans.
/g122Facilitates Faster Resolution : A well-prepared and accurate
IM reduces delays caused by information gaps, minimizes
disputes, and helps in timely submission and approval of
resolution plans.
/g122Improves Quality of Resolution Plan : The more detailed
and structured the IM, the higher the confidence among
applicants.This leads to better quality, higher-value resolution
plans being submitted.
The IM must include an overview of the company’s operations,
business performance, key contracts, and investment highlights. It
should also contain value-enhancing elements such as carried-
forward tax losses, unused GST credits, key employees, long-term
customer, vendor relationships, utility connections, and other
features that make the business viable as a going concern. These
disclosures make the process more transparent and help in better
price discovery, leading to more competitive resolution plans.
Recent regulatory changes require the IM to include more detailed
disclosures in specific areas:
/g122Tax Losses: The IM must show the amount of carried-forward
tax losses under the Income Tax Act, 1961, their classification
under different heads, and the time limits for utilising them.
/g122Avoidance Transactions : Any transactions identified as
preferential, undervalued, extortionate, or fraudulent, or cases
of wrongful trading, must be disclosed, including details of filings
made before the Adjudicating Authority. These transactions must
be made known to PRAs before submission of resolution plans.
The IM should be discussed in the CoC meetings. Any CoC member
may also request more information and the RP must share it with
all members in a timely manner. To help the RP prepare an accurate
IM, creditors are required to provide important data related to the
CD’s assets and liabilities. This includes relevant extracts of
valuation reports, stock and receivables statements, audit reports,
property inspection records, title search reports, financial
statements, bank account details etc. Creditors must also share
extracts from any audits they have carried out, such as stock audits,
transaction audits, or forensic audits. These inputs help in preparing
application for avoidance transactions, ensure correct asset
valuation thereby, leading to a complete and reliable IM.
The Hon’ble Supreme Court in Ebix Singapore Pvt. Ltd. v. CoC of
Educomp Solutions Ltd. & Anr. emphasized that the RP has a duty
to ensure that the IM contains accurate and complete information.
The Court noted that the RP must clarify if any information is
incomplete or subject to change. This makes it important to include
all relevant litigation, including arbitration cases, in the IM. The IM
should also disclose related party transactions as shown in the
financial statements. This helps the CoC and PRAs identify parties
who may be disqualified from submitting a resolution plan under
SECTION Section 10

Untitled Section

4.Vedik Ispat Private Limited 05-02-25 Bengaluru
C.11 Avoidance Transactions
The Code read with Regulations require the RPs and Liquidators
to file applications for avoidance of transactions, with the AA seeking
appropriate directions. 1442 applications seeking avoidance of
transactions have been filed with the AA till June 30, 2025 as
presented in Table 16.
INSOLVENCY AND BANKRUPTCY NEWS
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Table 16: Details of avoidance applications filed
(Amount in Rs. crore)
Sl.Nature of transactions Applications Filed
Number of transactions Amount involved
1 Preferential 211 29919.98
2 Undervalued 40 1818.01
3 Fraudulent 423 122370.48
4 Extortionate 4 75.65
5 Combination 764 235779.86
Total 1442 389963.98
D.Individual Processes
D.1 Insolvency Resolution Process
The provisions relating to insolvency resolution and bankruptcy
relating to PGs to CDs came into force on December 1, 2019. As
per the information received from the applicants, IPs, and data
collected from various benches of NCLT and Debt Recovery Tribunal
(DRT), 4276 applications have since been filed as of June 30, 2025,
for initiation of personal insolvency resolution process (PIRP) of
PGs to CDs. Out of them, 631 applications have been filed by the
debtors and 3645 applications by the creditors under sections 94
and 95 of the Code, respectively. Among them 51 have been filed
before different benches of Debt Recovery Tribunal (DRT) and 4225
have been filed before different benches of NCLT (Table 17).
Table 17: Insolvency Resolution of Personal Guarantors
(Amount in Rs. crore)
Period Applications filed by Total Adjudicatng
Debtors Creditors Authority
(u/s 94) (u/s 95)
No.Debt No. Debt No. Debt NCLT DRT
Amount Amount Amount
2019 - 20 4 1827.57 23 3299.82 27 5127.39 26 1
2020 - 21 27 3103.27 255 40384.58 282 43487.85 276 6
2021 - 22 88 3550.20 961 73057.07 1049 76607.27 1034 15
2022 - 23 88 10796.65 909 40355.88 997 51152.53 996 1
2023 - 24 250 5622.19 587 32897.84 837 38520.03 810 27
2024 - 25 173 5921.11 892 65204.19 1065 71125.30 1064 1
Apr - Jun, 2025 1 3.42 18 151.25 19 154.67 19 0
Total 631 30824.41 3645 255350.63 4276 286175.04 4225 51
Note: The data are provisional. These are revised on a continuous basis
as further information is received.
Debt data not available in 656 cases.
Of the 4276 applications, 121 applications have been withdrawn/
rejected/ dismissed before the appointment of RP and RPs have
been appointed in 1941 cases. After the appointment of RP , 149
cases have been withdrawn/ rejected/ dismissed, and 711 cases
have been admitted. The details are given in Table 18.
Table 18: Status of filed applications for initiation of Insolvency
Resolution Process of PGs to CDs
(Number)
Period No. of Before appointment No. of After appoint- No. of
appli- of RP cases ment of RP cases
cations No. of No. of where No. of No. of Admit-
filed Appli- Appli- RPs have Appli- Appli- ted
cations cations been cations cations
with dismissed/ appointed* with dismissed/
drawn rejected drawn rejected
2019 – 20 27 0 0 2 0 0 0
2020 – 21 282 6 1 35 2 1 13
2021 – 22 1049 15 15 469 0 7 35
2022 - 23 997 19 30 557 13 25 214
2023 – 24 837 12 19 595 19 18 179
2024 - 25 1065 1 3 232 6 44 239
Apr - Jun, 2025 19 0 0 51 4 10 31
Total 4276 53 68 1941 44 105 711
*This includes the admitted cases and cases, which are withdrawn or
dismissed or rejected after appointment of RP.
Out of the 711 admitted PIRPs, 216 have been closed. Of these,
12 have been withdrawn; 157 have been closed on non-submission
or rejection of repayment plan; and 44 have yielded approval of
repayment plan. In cases where repayment plans have been
approved, the creditors have realised Rs.102.78 crore, which is
2.16% of their admitted claims.
D.2 Bankruptcy Process
If the resolution process fails or repayment plan is not implemented,
the debtor or the creditor may make an application for initiation of
the bankruptcy process. As per the information received from the
applicants, IPs and data collected from various benches of NCLT
and DRT, 67 bankruptcy applications have since been filed as of
June 2025. Out of them, two applications are filed by the debtor
and 65 applications have been filed by the creditors under section
122 and 123 of the Code respectively. Among them, one application
has been filed before DRT, Chennai and 66 applications have been
filed before different benches of NCLT.
E.Service Providers
E.1 Insolvency Professionals
An individual, who is enrolled with an IPA as a professional member
and has the required qualification and experience and passed the
Limited Insolvency Examination, is registered as an IP. Pursuant
to the IBBI (Insolvency Professionals) (Amendment) Regulations,
2022 read with IBBI (Model Byelaws and Governing Board of
Insolvency Professional Agencies) (Amendment) Regulations,
2022, the Insolvency Professional Entities (IPEs) have been
permitted to be registered as IP to carry on the activities of an IP .
An IP needs an authorization for assignment (AFA) to take up an
assignment under the Code with effect from January 1, 2020.
The IBBI made available an online facility from November 16, 2019,
to enable an IP to make an application for issuance/renewal of AFA
to the concerned IPA. Thereafter, an IPA processes such applications
17
INSOLVENCY AND BANKRUPTCY NEWS
electronically.The details of IPs registered as on June 30, 2025, and
AFAs held by them, IPA-wise, are presented in Table 19.
Table 19: Registered IPs and AFAs as on June 30, 2025
City / Region Registered IPs IPs having AFA
IIIP ICSI IPA of Total IIIP ICSI IPA of Total
ICAI IIP ICMAI ICAI IIP ICMAI
New Delhi 507 295 97 899 205 123 46 374
Rest of Northern Region 521 220 90 831 191 98 30 319
Mumbai 445 157 43 645 181 68 17 266
Rest of Western Region 383 143 55 581 169 69 21 259
Chennai 158 90 24 272 60 38 13 111
Rest of Southern Region 455 238 95 788 158 92 47 297
Kolkata 249 43 29 321 120 19 17 156
Rest of Eastern Region 81 35 12 128 26 18 8 52
Total (Individual) 2799 1221 445 4465 1110 525 199 1834
Total (IPE as IP) 55 16 25 96 46 10 18 74
Grand Total 2854 1237 470 4561 1156 535 217 1908
Of the 4538 IPs registered till date, registrations of 15 IPs have
been cancelled through disciplinary action, and registrations of 24
IPs cancelled on failing to fulfil the requirement of fit and proper
person status. As per information available, 34 IPs have passed
away.The registrations and cancellations of registrations of IPs, till
June 30, 2025, are presented in Table 20.
Table 20: Registration and Cancellation of Registration of IPs
Year / Quarter Regis- Registered Cancelled during the Registered
tered during the period on account of at the
at the period Discip- Failing to fulfil Dea- end of
beginning linary the continuing th the
of the Process requirement of period
period ‘fit and proper
person’ status
2016 - 17 0 977 0 0 0 977
(Nov – Dec) #
2016 - 17 (Jan – Mar) 0 96 0 0 0 96
2017 – 18 96 1716 0 0 0 1812
2018 – 19 1812 648 4 0 0 2456
2019 – 20 2456 554 0 1 5 3004
2020 – 21 3004 506 0 1 5 3504
2021 – 22 3504 549 1 0 8 4044
2022 – 23 4044 209 2 0 5 4246
2023 – 24 4246 116 3 0 7 4352
2024 - 25 4352 114 5 22 4 4435
Apr - Jun, 2025 4435 30 0 0 0 4465
Total (Individual) NA 4538 15 24 34 4465
Total (IPE as IP) NA 96 0 0 0 96
Grand Total NA 4634 15 24 34 4561
# Registration with validity of six months. These registrations expired by
June 30, 2017.
An individual with 10 years of experience as a member of the ICAI,
ICSI, ICMAI or a Bar Council or 10 years of experience in the field
of law, after receiving a Bachelor’s degree in law or 10 years of
experience in management, after receiving a Master’s degree in
Management or two year full time Post Graduate Diploma in
Management or 15 years of experience in management, after
receiving a Bachelor’s degree is eligible for registration as an IP
on passing the Limited Insolvency Examination.
The Post Graduate Insolvency Programme (PGIP) is a first of its
kind programme for those aspiring to take up the profession of IP
as a career without having to wait for acquiring the specified 10/15
years of experience. The IBBI has granted approval to three
institutes to conduct PGIP - the Indian Institute of Corporate Affairs,
National Law Institute University, Bhopal and National Law
University, Delhi. The IBBI has granted 46 registrations based on
this qualification, until June 30, 2025.
Table 21 presents distribution of IPs as per their eligibility (an IP
may be a member of more than one Institute) as on June 30, 2025.
Of the 4465 IPs (individual) as on June 30, 2025, 460 IPs
(constituting about ten per cent of the total registered IPs) are
female.
Table 21: Distribution of IPs as per their Eligibility as on June
30, 2025
Eligibility No. of IPs (Individual)
Male Female Total
Member of ICAI 2215 224 2439
Member of ICSI 602 139 741
Member of ICMAI 186 19 205
Member of Bar Council 238 35 273
Managerial Experience 724 37 761
PGIP Qualified 40 6 46
Total 4005 460 4465
The Regulations provide that an IP (individual) shall be eligible to
obtain an AFA if he has not attained the age of 70 years. Table 22
presents the age profile of the IPs registered as on June 30, 2025.
Table 22: Age Profile of IPs (individual) as on June 30, 2025
Age Group Registered IPs IPs having AFA
( in Years) IIIP ICSI IPA of Total IIIP ICSI IPA of Total
ICAI IIP ICMAI ICAI IIP ICMAI
< 30 14 3 4 21 9 2 2 13
> 30 < 40 159 66 16 241 92 38 12 142
> 40 < 50 934 320 54 1308 381 144 25 550
> 50 < 60 845 378 107 1330 334 178 55 567
> 60 < 70 729 350 207 1286 294 163 105 562
> 70 < 80 112 96 54 262 NA NA NA NA
> 80 < 9 0 5 7 3 1 5N AN A N A N A
> 90 1 1 0 2 NA NA NA NA
Total 2799 1221 445 4465 1110 525 199 1834
NA: Not Applicable.
E.2 Replacement of IRP with RP
SECTION Section 11

Untitled Section

Section 22(2) of the Code provides that the CoC may, in its first
meeting, by a majority vote of not less than 66% of the voting share
of the FCs, either resolve to appoint the IRP as the RP or to replace
INSOLVENCY AND BANKRUPTCY NEWS
18
the IRP by another IP to function as the RP. Under section 22(4) of
the Code, the AA shall forward the name of the RP, proposed by
the CoC, under section 22(3)(b) of the Code, to IBBI for its
confirmation and shall make such appointment after such
confirmation.However, to save time in such reference, a database
of all the IPs registered with the IBBI has been shared with the AA,
disclosing whether any disciplinary proceeding is pending against
any of them and the status of their AFAs. While the database is
currently being used by various Benches of the AA, in a few cases,
the IBBI receives references from the AA and promptly responds
to it. Till June 30, 2025, as per updates available, a total of 1766
IRPs have been replaced with RPs, as shown in Figure 15. It is
observed that IRPs in about 35% of CIRPs initiated by CD are
replaced by RPs, in 32% of CIRPs initiated by OCs and in 22% of
CIRPs initiated by FCs.
Figure 15: Replacement of IRP with RP
E.3 Insolvency Professional Entities
During the quarter under review, no IPEs was recognised. As on
June 30, 2025, there were 127 IPEs (Table 23).
Table 23: IPEs as on June 30, 2025
Quarter No. of IPEs
Recognised Derecognised At the end
of the Period
2016 - 17 (Jan – Mar) 3 0 3
2017 – 18 73 1 75
2018 – 19 13 40 48
2019 – 20 23 2 69
2020 – 21 14 0 83
2021 – 22 10 2 91
2022 – 23 17 1 107
2023 – 24 15 0 122
2024 - 25 7 2 127
Apr - Jun, 2025 0 0 0
Total 175 48 127
E.4 Insolvency Professional Agencies
IPAs are front-line regulators and are responsible for developing
and regulating the insolvency profession. They discharge three
kinds of functions, namely, quasi-legislative, executive, and quasi-
judicial.The quasi-legislative functions cover laying down standards
and code of conduct through byelaws, which are binding on all
members.The executive functions include monitoring, inspection,
and investigation of professional members on a regular basis,
addressing grievances of aggrieved parties, gathering information
about their performance, etc., with the overarching objective of
promoting best practices and conduct by IPs. The quasi-judicial
functions include dealing with complaints against members and
taking suitable disciplinary actions.
As on June 30, 2025, there are three IPAs registered in accordance
with the Code and Regulations. The IBBI interacts with the Managing
Directors (MDs) of the IPAs and the IU every month, to obtain
feedback on areas of concern for the profession of IPs and discuss
the resolutions and the way forward. Table 24 presents the details
of activities by the IPAs. Table 25 gives details of number of
continuing professional education (CPE) hours earned by IPs.
Table 24: Activities by IPAs
Period Number of
Pre- CPE Training Other Discip- Compl-
regist- Progra- Work- Work linary aints
ration mmes shops shops/ Orders (Forwar-
Courses cond- for IPs Webinars/ Issued ded by
conducted ucted Roundtables/ IBBI)
Seminars Disposed
2018 – 19 16 - 7 100 4 11
2019 – 20 11 30 9 157 9 127
2020 – 21 14 193 66 102 42 102
2021 – 22 13 133 56 81 23 12
2022 – 23 15 231 104 192 85 125
2023 – 24 3 198 61 135 49 179
2024 - 25 3 250 92 161 30 115
Apr - Jun, 2025 1 67 23 44 7 55
Total 76 1102 418 972 249 726
Table 25: CPE Hours earned by the IPs
Period Number of CPE Hours earned
by members of
IIIP ICAI ICSI IIP IPA ICAI Total
2019 – 20 1160 695 320 2175
2020 – 21 18465 8746 4647 31858
2021 – 22 14123 7890 3872 25885
2022 – 23 22185 10732 3433 36350
2023 – 24 5803 9835 3715 19353
2024 - 25 14240 9125 3635 27000
Apr - Jun, 2025 3552 2431 595 6578
Total 79528 49454 20217 149199
Average CPE hours
per registered IP 28.41 40.50 45.43 33.42
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INSOLVENCY AND BANKRUPTCY NEWS
E.5 Information Utility
The Code provides that the data with the IU facilitates the CIRP .
The RoD of the IU provides evidence of debt and default and assists
the AA in deciding on an application for admission of insolvency
proceedings against a CD. Sections 7(3) & 9(3) of the Code read
with the Insolvency and Bankruptcy (Application to Adjudicating
Authority) Rules, 2016, require submission of RoD from an IU as
evidence of default, among various other options, along with
application for initiation of CIRP . The RoD issued by an IU has
evidentiary value in IBC processes. It contains complete details of
the parties to the debt, debt information, security details, default
information, details of communication with debtor and authentication
status by the counter parties of the debt categorized in accordance
with regulation 21 of the IBBI (Information Utilities) Regulations,
SECTION Section 12

Untitled Section

2017.The IU issues RoD in every defaulted loan (unique debt)
reported to it on completing the process of authentication.
There is one IU, namely, the NeSL that provides authenticated
financial information to the users. The IBBI interacts with the MD &
CEO of the IU along with the MDs of IPAs every month to discuss
the issues relating to receipt and authentication of financial
information.As at the end of June 2025, NeSL has issued about
1,37,780 RoDs under Corporate Segment to support the IBC
ecosystem.Figure 16 provides details of the registered users and
information with NeSL, as submitted by it.
Figure 16: Details of information with NeSL
E.6 Registered Valuer Organisations
The Companies (Registered Valuers and Valuation) Rules, 2017
(Valuation Rules) made under section 247 of the Companies Act,
2013 provide a unified institutional framework for development and
regulation of valuation profession. Its remit is limited to valuations
required under the Companies Act, 2013 and the Code. The IBBI
performs the functions of the Authority under the Valuation Rules.
It recognises Registered Valuer Organisations (RVOs) and registers
RVs and exercises regulatory oversight over them, while RVOs
serve as front-line regulators for the valuation profession.
An individual having specified qualification and experience needs
to enrol with an RVO, complete the educational course conducted
by the RVO and clear the examination conducted by IBBI, before
seeking registration with IBBI as an RV. There are currently 14
RVOs.The IBBI meets MDs / CEOs of RVOs every month to discuss
the issues arising from the valuation profession, to resolve queries
of the RVOs and to guide them in discharge of their responsibilities.
The details of individual RVs, RVO-wise, as on June 30, 2025, are
given in Table 26. A total of 5811 individuals have active registrations,
four of them are registered for all three asset classes, 89 are
registered for two asset classes and the balance 5718 are registered
for one asset class. As on June 30, 2025, the registration of four
RVs have been cancelled.
Table 26: Registered Valuers as on June 30, 2025 (Number)
Sl.Registered Valuer Organisation No. of Registration
granted in each Asset Class
Land & Plant & Securities Total
Build- Machi- or Financial
ing nery Assets
SECTION Section 13

Untitled Section

1.RVO Estate Managers and Appraisers 98 18 15 131
Foundation
SECTION Section 14

Untitled Section

2.IOV: IOV Registered Valuers Foundation 1699 264 197 2160
SECTION Section 15

Untitled Section

3.ICSI: ICSI Registered Valuers Organisation 0 0 258 258
SECTION Section 16

Untitled Section

4.IIV India registered Valuers Foundation 210 51 58 319
SECTION Section 17

Untitled Section

5.ICMAI: ICMAI Registered Valuers 68 34 322 424
Organisation
SECTION Section 18

Untitled Section

6.ICAI: ICAI Registered Valuers Organisation 3 1 1164 1168
SECTION Section 19

Untitled Section

7.PVAI: PVAI Valuation Professional 328 60 140 528
Organisation
SECTION Section 2

Untitled Section

Section 29A of the IBC and check whether the exemptions under
SECTION Section 20

Untitled Section

8.CVSRTA: CVSRTA Registered Valuers 196 61 0 257
Association
SECTION Section 21

Untitled Section

9.ACVA: Association of Certified Valuators 0 0 1 1
and Analysts*
SECTION Section 22

Untitled Section

10.CEV: CEV Integral Appraisers Foundation 170 47 3 220
SECTION Section 23

Untitled Section

11.DJF: Divya Jyoti Foundation 127 21 75 223
SECTION Section 24

Untitled Section

12.Nandadeep Valuers Foundation 7 0 1 8
SECTION Section 25

Untitled Section

13.IBVA: International Business Valuers 5 2 24 31
Association
SECTION Section 26

Untitled Section

14.AIVA: All India Valuers Association 2 0 0 2
SECTION Section 27

Untitled Section

15.AaRVF: Assessors and Registered Valuers 101 30 52 183
foundation
Total 3014 589 2310 5913
Note: Registration of 5 RVs have since been cancelled.
NA signifies that the RVO is not recognised for that asset class.
*The RVO has merged with IOV Registered Valuers Foundation and the
transfer of membership of members is under process.
RVs are permitted to form an entity (Partnership / Company) for
rendering valuation services. There are 122 such entities registered
as RVs as on June 30, 2025, as presented in Table 27. 57 of them
are registered for three asset classes, 23 are registered for two
asset classes and 42 are registered for one asset class. The
registration of RVs till June 30, 2025 is given in Table 28.
INSOLVENCY AND BANKRUPTCY NEWS
20
The average age of RVs as on June 30, 2025, stood at 48 years
across asset classes. It is 50 years for Land & Building, 56 years
for Plant & Machinery and 45 years for Securities or Financial Assets
(Table 30). Of the 5913 RVs as on June 30, 2025, 604 RVs
(constituting about 10% of the total RVs) are females.
Table 30: Age profile of RVs as on June 30, 2025
Age Group Land & Plant & Securities or Total
(in years) Building Machinery Financial
Assets
< 30 75 2 57 134
> 30 < 40 742 74 822 1638
> 40 < 50 520 119 765 1404
> 50 < 60 981 169 388 1538
> 60 < 70 609 150 244 1003
> 70 < 80 76 68 32 176
> 80 11 7 2 20
Total 3014 589 2310 5913
E.7 Complaints and Grievances
The IBBI (Grievance and Complaint Handing Procedure) Regulations,
2017 enable a stakeholder to file a grievance or a complaint against
a service provider. Beside this, grievance and complaints are received
from the Centralised Public Grievance Redress and Monitoring
System (CPGRAMS), Prime Minister’s Office (PMO), MCA, and other
authorities.The receipt and disposal of grievances and complaints
till June 30, 2025 is presented in Table 31.
Table 31: Receipt and Disposal of Grievances and Complaints
till June 30, 2025
(Number)
Year / Complaints and Grievances Received Total
Quarter Under the Through Through Recei- Dispo- Under
Regulations CPGRAM/PMO/ Other ved sed Exami-
MCA/Other Modes nation
Authorities
Rece- Dispo- Rece- Dispo- Rece- Dispo-
ived sed ived sed ived sed
2017 – 18 18 0 6 0 22 2 46 2 44
2018 – 19 111 51 333 290 713 380 1157 721 480
2019 – 20 153 177 239 227 1268 989 1660 1393 747
2020 – 21 268 260 358 378 990 1364 1616 2002 361
2021 – 22 276 279 574 570 611 784 1461 1633 189
2022 - 23 235 211 399 386 238 272 872 869 192
2023 – 24 209 193 435 452 311 271 955 916 231
2024 - 25 267 239 320 342 316 314 903 895 239
Apr-Jun, 2025 66 85 115 96 57 101 238 282 195
Total 1603 1495 2779 2741 4526 4477 8908 8713 195
E.8 Examinations
E.8.1 Limited Insolvency Examination
The IBBI publishes the syllabus, format, etc. of the examination
under regulation 3(3) of the IBBI (Insolvency Professionals)
Regulations, 2016. It reviews the same continuously to keep it
relevant with respect to dynamics of the market. It has successfully
completed seven phases of the Limited Insolvency Examination.
The eighth phase commenced on July 1, 2023, and concluded on
June 30, 2025. The ninth phase begins on July 1, 2025. It is a
Table 27: Registered Valuers (Entities) as on June 30, 2025
Registered Valuer Number Asset Class
Organisation of Entities Land & Plant & Securities
Building Machinery or Financial
Assets
RVO Estate Managers and Appraisers 6 6 4 5
Foundation
IOV Registered Valuers Foundation 43 37 33 35
ICSI Registered Valuers Organisation 6 2 2 6
IIV India Registered Valuers Foundation 3 3 3 2
ICMAI Registered Valuers Organisation 18 10 9 17
ICAI Registered Valuers Organisation 21 2 1 20
PVAI Valuation Professional Organisation 5 4 4 5
CVSRTA Registered Valuers Association 1 1 1 0
CEV Integral Appraisers Foundation 2 2 2 0
Divya Jyoti Foundation 3 2 2 3
All India Institute of Valuers Foundation 1 1 1 1
International Business Valuers Association 11 10 8 8
Nandadeep Valuers Foundation 1 1 1 1
Assessors and Registered Valuers foundation 1 1 1 1
Total 122 82 72 104
Table 28: Registration of RVs till June 30, 2025
(Number)
Year / Quarter Land & Plant & Securities or Total
Building Machinery Financial Assets
2017 – 18 0 0 0 0
2018 – 19 781 121 284 1186
2019 – 20 848 204 792 1844
2020 – 21 409 82 446 937
2021 – 22 302 67 303 672
2022 – 23 311 57 275 643
2023 – 24 138 23 89 250
2024 - 25 170 27 83 280
Apr-June, 2025 55 8 38 101
Total 3014 589 2310 5913
Note: Registration of 5 RVs have since been cancelled.
As on June 30, 2025, 1449 RVs (constituting 25% of the total RVs
registered) are from metros, while 4464 RVs (constituting 75% of
the total RVs registered) are from non-metro locations. The region-
wise detail of RVs is given in Table 29.
Table 29: Region wise RVs as on June 30, 2025
(Number)
City / Region Land & Plant & Securities or Total
Building Machinery Financial
Assets
New Delhi 93 39 271 403
Rest of Northern Region 506 102 407 1014
Mumbai 128 56 345 529
Rest of Western Region 888 177 398 1463
Chennai 123 46 165 334
Rest of Southern Region 1175 136 551 1862
Kolkata 38 20 125 183
Rest of Eastern Region 63 13 48 124
Total 3014 589 2310 5913
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INSOLVENCY AND BANKRUPTCY NEWS
computer based online examination available on daily basis from
various locations across India. NSEIT Limited is the current test
administrator.The details of the examination are given in Table 32.
Table 32: Limited Insolvency Examination
Phase Period Number of Attempts Successful
(some candidates made Attempts
more than one attempt)
First Jan, 2017 – Jun, 2017 5329 1201
Second Jul, 2017 – Dec, 2017 6237 1112
Third Jan, 2018 – Oct, 2018 6344 1013
Fourth Nov, 2018 – Jun, 2019 3025 505
Fifth Jul, 2019 – Dec, 2020 5860 1016
Sixth Jan, 2021 – Feb, 2022 2741 474
Seventh Mar, 2022 – Jun, 2023 1677 198
Eighth Jul, 2023 - Mar , 2024 380 58
Apr, 2024 - Jun, 2024 184 27
July, 2024 – Sept, 2024 192 35
Oct, 2024- Dec, 2024 157 25
Jan, 2025- Mar, 2025 190 28
Apr, 2025 – June, 2025 351 68
Total 32667 5760
E.8.2 Valuation Examinations
The IBBI, being the authority under the Valuation Rules commenced
the Valuation Examinations for asset classes of: (a) Land and Building,
(b)Plant and Machinery and (c) Securities or Financial Assets, on
March 31, 2018. It reviews the examinations continuously to keep it
relevant with the changing times. Presently, the fifth phase of valuation
examinations is going on from May 1, 2024. It is a computer based
online examination available from several locations across India.
National Institute of Securities Markets is the current test administrator.
The details of the Examinations are given in Table 33.
Table 33: Valuation Examinations
Phase Period Number of Attempts Number of Successful
(some candidates made Attempts in Asset Class
more than one attempt)
in Asset Class
Land & Plant & Securities Land & Plant & Securities
Building Machi- or Financial Building Machi- or Financial
nery Assets nery Assets
First Mar, 2018 – 9469 1665 4496 1748 324 707
Mar, 2019
Second Apr, 2019 – 3780 757 4795 380 95 656
May, 2020
Third Jun, 2020 – 8370 2015 8377 620 139 781
Jun, 2022
Fourth Jul, 2022 - 4042 764 2459 392 72 262
Apr, 2024
Fifth May, 2024 - 235 32 145 31 6 17
Jun, 2024
Jul,2024- 391 51 181 54 10 21
Sep, 2024
Oct 2024- 372 40 164 55 8 21
Dec, 2024
Jan - 2025 338 52 245 47 5 19
Mar - 2025
Apr - 2025 333 42 293 36 7 32
Jun - 2025
Total 27330 5418 21175 3363 666 2510
E.9 Disciplinary Orders
During the quarter, the Disciplinary Committee/Authority of the IBBI
disposed of 9 show cause notices issued to the IPs, 1 show cause
notice issued to RV and 2 appeals preferred by RVs for
contravention of the provisions of law, by passing suitable orders.
F.Orders
F.1 Supreme Court
Rakesh Bhanot Vs. M/s. Gurdas Agro Private Limited [Criminal
Appeal No. 1607 of 2025]
The appellant who was the director/ personal guarantor to CD had
issued a few cheques for discharge of liabilities of their legally
enforceable liability. As the said cheques were dishonoured for
insufficient funds, proceedings under section 138 of the Negotiable
Instruments Act, 1881 (NI Act) before the Judicial First Class
Magistrate Court were initiated by an operational creditor against
the personal guarantor to the CD. Thereafter, the personal guarantor
to CD had filed an application before AA under section 94 of IBC.
However, the application filed by the personal guarantor to CD
before the Judicial First Class Magistrate Court seeking stay on
the section 138 NI Act proceedings in view of the interim moratorium
under section 94 of IBC, was dismissed. Appeal filed against the
said order before the Punjab & Haryana HC was also dismissed.
On further appeal, the issue for consideration before SC was
whether proceedings under section 138 of NI Act, for cheque
dishonour, should be stayed with the filing of application under
SECTION Section 28

Untitled Section

section 94 of IBC and consequent application of interim moratorium
under section 96 of the IBC. SC observed that the moratorium under
sections 96 and 101 of the Code is intended to protect debtors
from civil debt recovery actions, not criminal prosecutions. It
distinguished between moratorium under section 14 of the Code,
which protects only the CD and that does not extend to shielding
individuals from criminal liability under section 138/141 of the NI
Act, whereas interim moratorium contemplated under section 96 is
to be derived from the object of the act, which is not to stall the
proceedings unrelated to the recovery of the debt. The protection
is not available against penal actions, the object of which is to not
recover any debt. SC observed that the object of moratorium is not
to stall criminal proceedings or any other proceedings which are
unrelated to the recovery of the debt. SC emphasised that the term
“any legal action or proceedings” does not mean “every legal action
or proceedings” and must be interpreted to mean only proceedings
concerning recovery of debt. Section 138 proceedings aim to uphold
the integrity of commercial transactions by holding individuals
accountable for cheque dishonour, a criminal act, and are not merely
debt recovery actions. SC, while dismissing the appeal, observed
that the statutory liability against the directors under section 138 of
the N.I. Act, is personal and hence, continues to bind natural
persons, irrespective of any moratorium applicable to the CD. The
acceptance of the resolution plan under section 31 of IBC or its
implementation thereof will have no effect on the prosecution under
SECTION Section 29

Untitled Section

section 138 of the NI Act, 1881.
Kalyani Transco Vs. Bhushan Power and Steel Limited. & Ors.
[Civil Appeal No. 1808 of 2020]
During the pendency of the application filed for approval of
resolution plan filed by JSW Steel Ltd (SRA) for Bhushan Power
INSOLVENCY AND BANKRUPTCY NEWS
22
and Steel Ltd (CD) before AA, criminal proceedings against the
suspended management of the CD were initiated by the
Enforcement Directorate (ED) under the PMLA on 25.04.2019.On
05.09.2019, AA approved the resolution plan submitted by SRA
with certain conditions. Post approval of the resolution plan, ED
passed a provisional attachment order (PAO) on 10.10.2019 by
attaching assets of the CD under the provisions of PMLA. Besides
the CoC challenging PAO, SRA also challenged the PAO of the ED
and certain conditions imposed by AA in the approved resolution
plan before the NCLAT. On 17.02.2020, the NCLAT, while staying
the said orders, upheld the resolution plan and dismissed appeals
filed by the OCs and ex-promoters of the CD. On appeal, the issues
before the SC were as follows: (1) Whether OCs and Ex-Promoters
are entitled to file appeals against the NCLAT order under section
62 of the Code and the SRA against the AA order, approving the
resolution plan, before the NCLAT? (2) Whether the eligibility of
SRA under section 29A of the Code and the compliance certificate
under Schedule – I was adequately verified by the RP? (3) Whether
NCLAT had any powers of judicial review over the decision taken
of ED under the PMLA? (4) Whether the RP filed the application
for approval of the plan within the timeline prescribed under section
12 of IBC? (5) Did the plan comply with mandatory requirements,
of section 30(2) of IBC and ensured priority payment to OCs, and
feasibility, viability, of the plan (6) Can the SRA justify the significant
delay (over 2 years) in implementing the plan by citing pending
litigation and then claim fait accompli after making delayed
payments? SC while rejecting the resolution plan of the SRA, held
as follows: (1) Since CIRP is a collective proceeding (in rem) and
OCs and ex-promoters are necessary stakeholders in the CIRP of
the CD whose appeals have been dismissed by the NCLAT, they
are “persons aggrieved” for the purpose of section 62 and their
appeals are maintainable before the SC. Moreover, SRA wasn’t
‘aggrieved’ by the approval itself, and none of the grounds under
SECTION Section 3

Untitled Section

Section 32A apply. Including this information improves transparency
and helps maintain the integrity of the resolution process.
To conclude, it is critical that PRAs have access to complete,
reliable, and timely information about the corporate debtor.
Disclosures about financial condition, tax benefits, business
operations, and strategic assets help shape the valuation and
bidding strategy. A high quality IM builds trust among resolution
applicants, encourages more participation, and leads to stronger
and more competitive resolution plans. By reducing information
gaps and encouraging informed participation, the IM helps ensure
that the resolution process is transparent, efficient, and focused
on maximizing value, as intended under the IBC.
Ravi Mital
The Information Memorandum
3
INSOLVENCY AND BANKRUPTCY NEWS
A.IBBI Updates
A.1 Key Events
IP Conclave
The Insolvency and Bankruptcy Board of India (IBBI) organised
11th Conclave of Insolvency Professionals (IPs) on May 9, 2025, at
the India International Centre, New Delhi. The Conclave provided
a platform for dialogue and collaboration among stakeholders to
discuss recent developments regarding reviewing of various
statutory forms to reduce the compliance requirements of IPs. An
interactive session was held, wherein suggestions were noted for
strengthening and improving the efficiency of the IBC ecosystem.
IP Conclave, New Delhi, May 9, 2025
IP Conclave, New Delhi, May 9, 2025
International Yoga Day
The IBBI observed the International Yoga Day on June 21, 2025.
An online yoga session was conducted to promote peace and
reconciliation in mind, body, and spirit for the health and wellness
of the employees of the Board by Mr. Ajay Kumar Jain, Insolvency
Professional, Yoga Wellness Instructor. The Yoga Session included
practicing Yogasans, Pranayam and Meditation.
A.2 Employee Trainings and Workshops
The members and officers of IBBI attended the following workshops
and training programmes.
Date Organised Nature of the No. of
by programme/ Subject officers
23-24 April, International Indonesia International 6
2025 Valuation Valuation Conference (IIVC)
Standards 2025
Council
(IVSC)
B.Legal and Regulatory Framework
B.1 Regulations
Amendment to IP Regulations
The IBBI notified the Insolvency and Bankruptcy Board of India
(Insolvency Professional) (Amendment) Regulations, 2025 on April
03, 2025. The amendment relaxed the timeline for submission of
application for enrolment with the insolvency professional agency
(IPA) from the existing twelve months to twenty-four months to
provide greater flexibility and facilitate better career planning for
aspiring IPs for applying for enrolment-cum-registration to the IPAs.
These aspiring IPs particularly include:
(a)Post-Graduate Insolvency Programme (PGIP) students, who
previously had to wait until their final year to take the exam, as
passing early would result in the validity of 12 months expiring before
course completion, which is of two years.
(b)Working professionals such as Chartered Accountants (CAs),
Company Secretaries (CSs), Cost and Management Accountants
(CMAs), lawyers, and finance professionals, who need time to gain
relevant experience and plan their career trajectory effectively and
align the enrolment-cum-registration with their professional
commitments.
Amendment to CIRP Regulations
The Insolvency and Bankruptcy Board of India (IBBI) notified the
Insolvency Resolution Process for Corporate Persons (Second
Amendment) Regulations, 2025, on April 3, 2025. The amendment
provides for revised Form-H, the compliance certificate submitted
by the Resolution Professional (RP) along with the application for
approval of resolution plan to the Adjudicating Authority (NCLT),
certifying compliance with the IBC and related regulations. The
revised Form-H now, inter alia, captures detailed information on
the Successful Resolution Applicant’s (SRA’s) business, financial
capacity, implementation details,key financial metrics, carry-forward
of losses under the Income Tax Act, and regulatory fees payable to
the Board.
Further, the Insolvency and Bankruptcy Board of India (IBBI) has
notified the Insolvency and Bankruptcy Board of India (Insolvency
Resolution Process for Corporate Persons) (Third Amendment)
Regulations, 2025 on May 19, 2025, which came into effect from
June 1, 2025. This amendment replaces Regulation 40B of the
CIRP Regulations, 2016 and introduces a revised framework for
INSOLVENCY AND BANKRUPTCY NEWS
4
the electronic filing of forms by the IRPs/RPs.The revised framework
replaces the existing nine forms (IP-1 and CIRP Forms 1 to 8) with
five consolidated forms (CP-1 to CP-5) aligned with key stages of
the CIRP, each with specific filing responsibilities and timelines.The
new forms introduce a standardised monthly reporting cycle and
are designed to enhance monitoring while reducing the burden on
insolvency professionals.
The Insolvency and Bankruptcy Board of India (IBBI), has further,
notified the Insolvency and Bankruptcy Board of India (Insolvency
Resolution Process for Corporate Persons) (Fourth Amendment)
Regulations, 2025, on May 26, 2025. The amendment regulations
provide for the following:
(i)The resolution professional, with the approval of the CoC, can
invite expression of interest for submission of resolution plans
for the corporate debtor as a whole, or for sale of one or more
of assets of the corporate debtor, or for both. By enabling
concurrent invitations, the resolution process aims to reduce
timelines, prevent value erosion in viable segments, and
encourage broader investor participation.
(ii) Where a resolution plan provides for payment in stages, the
financial creditors who did not vote in favour of the resolution
plan shall be paid at least pro rata and in priority over financial
creditors who voted in favour of the plan, in each stage. This
approach balances the legitimate rights of dissenting creditors
with the practical constraints of phased implementations.
(iii) The CoC may direct the resolution professional to invite interim
finance providers to CoC meetings as observers (without voting
rights), enabling them to better assess the corporate debtor’s
operations and make informed funding decisions.
(iv) The Resolution professionals are now required to present all
resolution plans received, including those that are non-
compliant, to the CoC along with relevant details. This provision
ensures that the CoC has access to comprehensive information
for decision-making, which may lead to more informed choices
and ultimately contribute to a more transparent and effective
resolution process.
Amendment to PG to CD Regulations
The Insolvency and Bankruptcy Board of India (IBBI) notified the
Insolvency and Bankruptcy Board of India (Insolvency Resolution
Process for Personal Guarantors to Corporate Debtors)
(Amendment) Regulations, 2025, on May 19, 2025, introducing
Regulation 17B to address procedural gaps in cases where a debtor
fails to submit a repayment plan under Section 105 of the Insolvency
and Bankruptcy Code, 2016. It provides that the resolution
professional, with the approval of creditors, shall file an application
with the Adjudicating Authority to report the non-submission and
seek appropriate directions, thereby enhancing clarity and efficiency
in the insolvency resolution process for personal guarantors to
corporate debtors.
B.2 Circulars
Launch of Revised Forms for Corporate Insolvency Resolution
Process (CIRP)
Pursuant to the Insolvency and Bankruptcy Board of India
(Insolvency Resolution Process for Corporate Persons) (Third
Amendment) Regulations, 2025 dated May 19, 2025, IBBI issued
a circular on May 26, 2025, providing for the revised forms for the
Corporate Insolvency Resolution Process (CIRP) effective from
June 1, 2025. The revised framework replaces the existing nine
forms (IP-1 and CIRP Forms 1 to 8) with five consolidated forms
(CP-1 to CP-5) to eliminate redundancies and enable auto-
population of data through the IBBI portal. The IP handling the CIRP
assignment shall access the platform with a unique username and
password provided by the IBBI and submit the Forms. To facilitate
compliance, Frequently Asked Questions (FAQs) have been made
available on the IBBI website, and IPs can report any technical
issues in filing to the designated support email.
B.3 Guidelines
Guidelines for Panel of IPs
The IBBI issued the ‘Insolvency Professionals to act as Interim
Resolution Professionals, Liquidators, Resolution Professionals,
and Bankruptcy Trustees (Recommendation) Guidelines, 2025’ on
May 27, 2025. These guidelines enable the Board to prepare a
common panel of IPs and share the same with the AA for
appointment of Interim Resolution Professionals (IRPs), Resolution
Professionals (RPs), Liquidators and Bankruptcy Trustees (BTs)
from July 1, 2025, to December 31, 2025.
B.4 Invitation of public comments
Suggestions to simplify, ease and reduce cost of compliance
of Regulations notified under the IBC
The Insolvency and Bankruptcy Board of India (IBBI), via a press
release dated 7th April 2025, invited online suggestions from the
public and stakeholders on all regulations issued under the
Insolvency and Bankruptcy Code, 2016. This exercise was
undertaken in line with Regulation 7 of the IBBI (Mechanism for
Issuing Regulations) Regulations, 2018, and in pursuance of the
Union Budget 2023–24 announcement, which called upon financial
sector regulators to conduct a comprehensive review of existing
regulations.The last date for submitting the suggestions was 30
th
June 2025.
C.Corporate Processes
The data provided in this section regarding corporate processes is
provisional, as it is getting revised on a continuous basis depending
on the flow of updated information as received from IPs or the
information in respect of process changes. For example, a process
may ultimately yield an order for liquidation even after approval of
resolution plan or may ultimately yield resolution plan even after
an order for liquidation.
C.1 Overview
The provisions relating to CIRP came into force on December
1, 2016. The details of CIRP cases admitted and closed, as at the
end of June, 2025 are given in Table 1 and Figures 1-2. Sectoral
distribution of CDs under CIRP is presented in Figures 3-6.
The Code has rescued 3763 CDs (1258 through resolution plans,
1314 through appeal or review or settlement and 1191 through
withdrawal) till June, 2025. It has referred 2824 CDs for
liquidation.The resolved CDs resulted in realisation of more than
5
INSOLVENCY AND BANKRUPTCY NEWS
32.57% as against the admitted claims and more than 170.84% as
against the liquidation value. Resolution plans on average are
yielding 94.89% of fair value of the CDs. Till June, 2025, 1439 CDs
have been completely liquidated. These 1439 CDs together had
outstanding claims of Rs.4.26 lakh crore, but the assets valued at
Rs.0.17 lakh crore. The liquidation of these companies resulted in
90.3% realisation as against the liquidation value.
Table 1: Details of CIRP cases as on June 30, 2025
Status of CIRPs No. of CIRPs
Admitted 8492
Closure:
Withdrawn under section 12A 1191
Closed on appeal or review or settled 1314
Resolution plans approved 1258
Liquidation orders passed 2824
Ongoing CIRP cases 1905
Note: This excludes 1 CD which has moved directly from Board for Industrial
and Financial Reconstruction (BIFR) to resolution.
Source: Compilation from website of the NCLT and filing by IPs.
Figure 1: Corporate Insolvency Resolution Process
Figure 2: Mode of closure of CIRPs
Figure 3: Sectoral distribution of CIRPs: Admission
Commencement
of Liquidation
(43%)
Resolved/ Appeal/
Review/ Settled/
Withdrawn (57%)
Figure 4: Sectoral distribution of CIRPs: Appeal/
Review/ Settled/ Withdrawn
Figure 6: Sectoral distribution of CIRPs:
Commencement of liquidation
Figure 5: Sectoral distribution of CIRPs: Resolution
plans
INSOLVENCY AND BANKRUPTCY NEWS
6
The outcome of CIRPs, initiated stakeholder-wise, as on June 30,
2025 is presented in Table 2. Of the OC initiated CIRPs that were
closed, around 52% were closed on appeal, review, or withdrawal.
Such closures accounted for more than 68% of all closures by
appeal, review, or withdrawal.
Table 2: Outcome of CIRPs, initiated Stakeholder-wise, as on
June 30, 2025
Outcome Description CIRPs initiated by/for
FCs OCs CDs FiSPs Total
Status of Closure by Appeal/Review/ 415 887 12 0 1314
CIRPs Settled
Closure by Withdrawal u/s 12A 358 825 8 0 1191
Closure by Approval of Resolution 768 399 87 4 1258
Plan
Closure by Commencement of 1326 1193 305 0 2824
Liquidation
Ongoing 1135 659 110 1 1905
Total 4002 3963 522 5 8492
CIRPs Realisation by Creditors as % of 187.5 128.8 146.8 134.9 170.8
yielding Liquidation Value
Resolution Realisation by Creditors as % of 33.0 25.0 18.3 41.4 32.6
Plans their Claims
Average Time taken for Closure 729 738 625 677 724
of CIRP
CIRPs Liquidation Value as % of Claims 5.5 8.3 7.5 - 6.1
yielding Average Time taken for order of 522 515 456 - 512
Liquidations Liquidation
C.2 Ratio of Resolution and Liquidation orders
A number of initiatives are being taken to improve the outcomes of
the Code. These include monitoring of cases pending for admission
and ongoing CIRPs. Further, the IBBI revised its mechanisms for
real-time sharing of information regarding applications for the
initiation of CIRP with the IU. These initiatives have had a substantial
impact on the IBC process, as evidenced by the increase in NCLT-
approved resolutions and the admission of cases initiated by FCs.
Figure 7 below highlights the improvement in ratio of number of
cases ending with resolution vis-à-vis cases in which liquidation is
ordered till the quarter April - June, 2025.
C.3 Stakeholder-wise initiation of CIRP
The distribution of stakeholder-wise initiation of CIRPs is presented
in Table 3. FCs triggered 47.15% of the CIRPs, followed by about
46.69% by OCs and remaining by the CDs. It is observed that about
80% of CIRPs having an underlying default of less than Rs. 1 crore
were initiated on applications by OCs while about 80% of CIRPs
having an underlying default of more than Rs. 10 crores were
initiated on applications by FCs. The share of CIRPs initiated by
CDs is declining over time.
Table 3: Year-wise and Stakeholder-wise Initiation of CIRPs
Period CIRP initiated by Total
FC OC CD
2016 - 17 8 7 22 37
2017 - 18 286 310 111 707
2018 - 19 517 569 71 1157
2019 - 20 883 1056 51 1990
2020 - 21 197 317 22 536
2021 - 22 372 474 43 889
2022 - 23 654 538 70 1262
2023 – 24 535 402 66 1003
2024 - 25 450 226 55 731
April - Jun, 2025 100 64 11 175
Total 4002 3963 522 8487
Note: This excludes five cases wherein applications filed by the RBI were
admitted u/s 227 of the Code.
C.4 Timelines
C.4.1 For Concluded Processes
The Code endeavours to close the various processes at the
earliest.The 1258 CIRPs, which have yielded resolution plans by
the end of June, 2025 took on average 602 days (after excluding
the time excluded by the AA) for conclusion of process, while
incurring an average cost of 1.11% of liquidation value and 0.63%
of resolution value. Similarly, the 2824 CIRPs, which ended up in
orders for liquidation, took on average 512 days for conclusion.
Further, 1439 liquidation processes, which have closed by
submission of final reports took on average 651 days for closure.
Similarly, 1746 voluntary liquidation processes, which have closed
by submission of final reports, took on average 400 days for
closure.
The average time taken for completion of various processes is
presented in Table 4.
Figure 7: Ratio of Resolution and Liquidation
Orders
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INSOLVENCY AND BANKRUPTCY NEWS
Table 4: Average Time for Approval of Resolution Plans/Orders for Liquidation
Time (In days)
Sl.Average time As on March, 2024 As on March, 2025 April – June, 2025
No.of Time No. of Time No. of Time
Processes Including Excluding Processes Including Excluding Processes Including Excluding
covered excluded excluded covered excluded excluded covered excluded excluded
time time time time time time
CIRPs
1 From ICD to approval of 935 674 562 1198 717 599 60 865 694
resolution plans by AA
2 From ICD to order for 2469 491 NA 2759 507 NA 65 714 NA
Liquidation by AA
Liquidations
3 From LCD to submission of final 1087 604 NA 1407 645 NA 32 914 NA
report under Liquidation
4 From LCD to submission of 1409 410 NA 1711 401 NA 35 297 NA
final report under Voluntary
Liquidation
5 From LCD to order for 700 733 NA 931 778 NA 28 1054 NA
dissolution under Liquidation
6 From LCD to order for 959 723 NA 1218 736 NA 61 872 NA
dissolution under Voluntary
Liquidation
C.5 Resolution Plans
C.5.1 Overall outcomes
Till FY 2024-25, 1194 CIRPs had yielded resolution plans. The
creditors realised Rs. 3.89 lakh crore under the resolution plans, in
these cases. The liquidation value of the assets available with these
CDs, when they entered the CIRP , was at Rs. 2.29 lakh crore against
the total claims of the creditors worth Rs. 11.87 lakh crore. The
realisation to the creditors was 32.76% and 170.09% as against
their admitted claims and liquidation value, respectively.
During the quarter April - June, 2025, 06 more CIRPs was reported
as yielding resolution plan, pertaining to the prior period, as
presented in Part A of Table 5. 60 CIRPs yielded resolution plans
during the quarter April - June, 2025, the details of which are
presented in Part B of Table 5. 02 CDs which had earlier yielded
resolution have since either moved into liquidation or the process
has been ordered to be restarted, taking the total resolution plans
approved to 1258 till June,2025.
C.4.2 For Ongoing CIRPs
The status of ongoing CIRPs in terms of time taken, as of June,
2025, is presented in Figure 8.
Figure 8: Timeline: Ongoing CIRPs
Table 5: CIRPs Yielding Resolution Plans
Sl.Name of Corporate Debtor Defunct Date of Date of CIRP Amount (in Rs.crore) Realisable Value as % of
(Yes / Commen- Approval initiated Total Liquid- Fair Total Admit- Liquid - Fair
No) cement of Resolu- by Admitted ation Value Realisable ted ation Value
of CIRP tion Plan Claims Valu e Amount by Claims Value'
Claimants
Part A: Reported for Prior Period (Till March, 2025)
1 Athena Demwe Power Limited No 28-09-2017 18-03-2025 FC 568.06 5.85 427.86 568.06 100.00 9718.54 132.77
2 Delhi Control Devices Private Limited No 15-02-2019 28-09-2022 OC 222.19 25.37 34.05 20.71 9.32 81.63 60.81
3 Avail Holding Limited Yes 29-01-2024 18-03-2025 OC 3.43 0.26 0.53 1.50 43.77 567.29 283.70
4 Samvid Steels Private Limited Yes 17-04-2024 27-01-2025 FC 15.29 5.39 6.74 6.69 43.79 124.09 99.27
INSOLVENCY AND BANKRUPTCY NEWS
8
5 Konkan Minerals Private Limited NA 16-08-2017 31-07-2024 CD 0.00 - - 0.00 - - -
6 Sainath Estates Private Limited NA 08-07-2019 24-02-2025 FC 0.00 - - 0.00 - - -
Part B: For April - June, 2025
1 Vadraj Cement Limited Yes 02-02-2024 01-04-2025 FC 9633.95 1080.00 1668.00 1756.52 18.23 162.64 105.31
2 Smartering Infratech Private Limited Yes 29-09-2022 04-04-2025 OC 46.09 3.86 4.64 5.20 11.28 134.60 111.96
3 Jabalpur Msw Private Limited No 14-09-2023 04-04-2025 FC 112.62 54.19 86.51 65.45 58.12 120.79 75.66
4 Osian’s - Connoisseurs of Art Private Limited No 09-12-2021 07-04-2025 FC 559.44 15.83 21.84 30.70 5.49 193.96 140.58
5 AAA Facilities Solution Private Limited No 31-07-2023 07-04-2025 OC 1.36 11.03 13.79 2.36 173.78 21.36 17.08
6 Jassi Properties & Construction Private Limited Yes 01-03-2024 08-04-2025 OC 16.52 0.43 0.57 1.58 9.57 371.75 275.45
7 Madurai Krishna Network Private Limited No 22-07-2022 08-04-2025 OC 10.16 3.39 3.54 5.26 51.78 155.17 148.71
8 Jr Agrotech Private Limited No 27-07-2018 23-04-2025 FC 320.32 20.30 34.89 32.10 10.02 158.12 92.00
9 Gactel Turnkey Projects Limited Yes 27-03-2024 24-04-2025 OC 377.68 0.00 0.00 10.99 2.91 - -
10 Cambridge Energy Resources Private Limited No 26-03-2021 25-04-2025 OC 36.76 12.26 15.44 9.75 26.51 79.46 63.13
11 BTT Industries Private Limited Yes 15-10-2019 28-04-2025 FC 54.12 2.17 2.44 1.43 2.64 66.00 58.62
12 Starwort Engineers Private Limited Yes 16-07-2024 29-04-2025 FC 19.51 0.13 0.13 0.25 1.28 190.19 190.19
13 Shree Rudra Shakti Industries Private Limited Yes 14-05-2019 30-04-2025 OC 2.30 0.00 0.00 2.04 89.02 - -
14 Dhara Techno system LLP Yes 11-08-2023 30-04-2025 OC 36.73 0.00 0.00 0.30 0.82 - -
15 Singhal Strips Limited No 30-10-2023 30-04-2025 OC 133.06 17.42 22.86 22.83 17.16 131.06 99.87
16 Rubique Technologies India Private Limited Yes 07-10-2020 02-05-2025 OC 9.41 0.14 0.96 0.84 8.92 585.17 87.92
17 Jay Formulations Ltd No 26-09-2023 05-05-2025 FC 105.81 17.09 44.85 19.08 18.03 111.67 42.54
18 Sheel Auto Industries Private Limited Yes 25-08-2023 06-05-2025 CD 8.27 2.93 4.18 2.75 33.30 93.92 65.91
19 Bvm Finance Private Limited Yes 08-02-2024 06-05-2025 FC 63.60 0.35 0.43 7.99 12.56 2311.69 1868.41
20 Smaaash Entertainment Private Limited No 06-05-2022 07-05-2025 FC 453.19 65.77 108.32 127.07 28.04 193.20 117.31
21 Unistar Tradelink Private Limited NA 19-05-2023 07-05-2025 CD 0.00 - - 0.00 - - -
22 Varadharaja Foods Private Limited Yes 09-11-2022 08-05-2025 OC 19.77 6.86 9.80 4.17 21.09 60.83 42.57
23 Tirupathi Properties and Investment Private Limited Yes 13-08-2024 13-05-2025 FC 26.48 20.92 27.00 25.00 94.40 119.50 92.60
24 Gajanand Corporation Private Limited Yes 22-02-2022 14-05-2025 OC 32.13 0.20 0.24 0.13 0.40 63.97 52.85
25 Premshree Prime Properties Private Limited NA 17-02-2023 14-05-2025 FC 0.00 - - 0.00 - - -
26 Bostin Engineers Pvt Ltd No 01-04-2024 22-05-2025 FC 61.26 5.80 7.53 5.86 9.57 101.04 77.84
27 Topworth Urja & Metals Limited NA 12-08-2022 26-05-2025 FC 0.00 - - 0.00 - - -
28 NSL Nagapatnam Power and Infratech Limited No 18-01-2018 27-05-2025 CD 258.44 15.83 74.43 170.76 66.07 1078.73 229.41
29 Slimline Realty Private Limited No 15-05-2024 30-05-2025 FC 138.38 3.87 4.08 5.64 4.08 145.69 138.41
30 Servel India Private Limited NA 08-06-2020 03-06-2025 OC 0.00 - - 0.00 - - -
31 Trident Sugars Limited NA 09-07-2024 04-06-2025 FC 0.00 - - 0.00 - - -
32 Astral Steritech Private Limited NA 10-06-2024 05-06-2025 OC 0.00 - - 0.00 - - -
33 Shree Gopinath Paper Mills Private Limited No 20-06-2024 05-06-2025 FC 56.36 14.97 21.38 16.70 29.63 111.59 78.13
34 Reward Business Solutions Private Limited No 18-02-2021 06-06-2025 FC 107.10 56.80 79.34 61.93 57.82 109.02 78.05
35 India Mega AgroAnaj Limited No 16-11-2022 12-06-2025 FC 375.39 25.59 38.62 24.22 6.45 94.65 62.71
36 Nadhi Bio Products Private Limited Yes 26-05-2023 12-06-2025 FC 145.31 47.37 72.21 89.53 61.61 189.00 123.99
37 Taaza International Limited Yes 01-10-2024 12-06-2025 FC 6.02 0.00 0.00 6.02 100.00 - -
38 B.P. Bansal Agritech Private Limited No 01-12-2022 12-06-2025 FC 271.76 11.51 13.68 11.50 4.23 99.95 84.04
39 Tarapur Textile Park Limited NA 06-12-2022 12-06-2025 FC 0.00 - - 0.00 - - -
40 PCL Foods Private Limited NA 22-12-2023 12-06-2025 FC 0.00 - - 0.00 - - -
41 Pabitra Enclave Private Limited No 14-11-2024 13-06-2025 FC 2.79 2.11 2.87 2.38 85.03 112.76 82.85
42 DBG Leasing and Housing Limited NA 16-11-2022 13-06-2025 FC 0.00 - - 0.00 - - -
43 T & U Systems Automobiles Private Limited Yes 09-01-2024 17-06-2025 CD 17.33 0.00 0.00 0.11 0.63 - -
44 Best It World (India) Private Limited NA 22-05-2024 17-06-2025 FC 0.00 - - 0.00 - - -
45 Indison Agro Foods Limited Yes 03-03-2023 18-06-2025 FC 588.28 13.63 19.09 21.76 3.70 159.64 113.94
46 Vidarbha Industries Power Limited No 30-09-2024 18-06-2025 FC 6753.92 1263.50 1718.89 3585.45 53.09 283.77 208.59
47 Majestic Research Services and Solutions Limited NA 25-05-2023 20-06-2025 FC 0.00 - - 0.00 - - -
48 Envirant Developers Private Limited Yes 19-05-2023 25-06-2025 FC 99.27 57.34 73.77 68.95 69.45 120.24 93.46
49 Darshan Developers Private Limited NA 26-07-2021 27-06-2025 OC 0.00 - - 0.00 - - -
9
INSOLVENCY AND BANKRUPTCY NEWS
Resolution
plans
approved
50 Immediate Real Estate Private Limited NA 06-09-2022 27-06-2025 FC 0.00 - - 0.00 - - -
51 Manpreet Developers Private Limited NA 11-01-2023 27-06-2025 FC 0.00 - - 0.00 - - -
52 Wamika Real Estate Private Limited NA 03-03-2023 27-06-2025 FC 0.00 - - 0.00 - - -
53 Prithvi Residency Private Limited NA 03-03-2023 27-06-2025 FC 0.00 - - 0.00 - - -
54 Tenacity Real Estate Private Limited NA 03-03-2023 27-06-2025 FC 0.00 - - 0.00 - - -
55 Ghardwar Real Estate Private Limited NA 03-03-2023 27-06-2025 FC 0.00 - - 0.00 - - -
56 Fulgent Real Estate Private Limited NA 03-03-2023 27-06-2025 FC 0.00 - - 0.00 - - -
57 Suvarat Real Estate Developers Private Limited NA 03-03-2023 27-06-2025 FC 0.00 - - 0.00 - - -
58 Azinova Constructions Private Limited NA 03-03-2023 27-06-2025 FC 0.00 - - 0.00 - - -
59 Vyomakara Real Estate Private Limited NA 03-03-2023 27-06-2025 FC 0.00 - - 0.00 - - -
60 Legend Power Private Limited NA 22-07-2024 30-06-2025 FC 0.00 - - 0.00 - - -
Total (April - June, 2025) 20960.90 2853.58 4196.32 6204.60 29.60 217.43 147.86
Total (Till June, 2025) 1215445.12 231717.03 350070.93 395874.45 32.57 170.84 94.89*
Notes:
SECTION Section 30

Untitled Section

section 61(3) of the Code (e.g., contravention of law, material
irregularity by RP, etc) were available to challenge conditions of
the resolution plan which were unfavourable to SRA (2) RP has
merely reproduced the clauses of the resolution plan and did not
submit the Compliance Certificate under Form - H of the Schedule
I of the CIRP Regulations, 2016. Moreover, the RP has failed to
determine the eligibility of the SRA as required under section 29A
of the Code since the document submitted by the RP nowhere
stated about eligibility of SRA (3) PMLA being a public law, neither
the AA nor the NCLAT is vested with the powers of judicial review
over the decision taken by the Government or Statutory Authority
in relation to a matter which is in the realm of public law. Thus, the
proceedings initiated by the ED cannot be brought within the fold
of the phrase “arising out of or in relation to the insolvency resolution”
under section 60(5)(c) of the Code. (4) RP utterly disregarded the
timeline to complete the CIRP under section 12 on the false pretext
of an appeal filed by the PRA which was pending for adjudication
before the NCLAT, albeit the NCLAT had permitted the RP to
proceed with approval of plan. Moreover, the RP failed to explain
the delay of four months in placing the plan before the AA for
approval, after the CoC had approved the plan (5) Plan violated
regulation 38 of the CIRP Regulations, 2016 by not prioritizing OC
payments over FCs and did not ensure compliance of the plan
before submitting it to CoC as required under section 30(2) of the
Code.(6) SRA has instituted vexatious and frivolous litigations
before the AA and NCLAT, which led to delay in the implementation
of the resolution plan under the garb of pendency of appeal before
the Courts. Further, the SC castigated the CoC for making a volte-
face by accepting Rs. 19,350 crores from the SRA at a very belated
stage, when they initially implicated the SRA for demonstrating ill-
intent and malafides to mislead and misuse the process of Court in
order to delay the implementation of the plan. In terms of sub-section
(1)of section 33, and in exercise of the jurisdiction conferred under
SECTION Section 31

Untitled Section

Article 142 of the Constitution of India, the AA was directed to initiate
the liquidation proceedings of CD.
SRA filed an SLP seeking leave of SC to file a review petition before
the expiry of limitation against SC’s judgment in Civil Appeal No.
1808 of 2020. SC has ordered a status quo on the liquidation of the
CD to avoid future legal complications.
National Spot Exchange Limited Vs. Union of India & Ors. [Writ
Petition (Civil) No. 995 of 2019]
National Spot Exchange Limited (“NSEL/Decree Holder”) is an
electronic commodity trading platform where trading happened in
paired contracts, with investors, buying a spot contract and selling
a futures for the same commodity, through brokers by following
settlement methodology of pay-in obligations to exchange. The
NSEL had launched contracts for buying and selling of commodities
with different settlement periods, wherein the delivery of the
commodity and payment of price (i.e., settlement of transaction)
was to be affected by the buying and the selling member as the
case may be. Thereafter, the funds “pay – in” obligation would be
intimated to the NSEL members whose clients purchased the
commodities, and the funds “pay – out” obligation would be
intimated to the NSEL members whose clients sold the commodities.
Based on the intimation from the exchange, the clients would have
to fulfil their respective obligations through the NSEL members,
through whom they have traded on the NSEL. In 2013, the NSEL
encountered a crisis when 13,000 traders alleged that 24 trading
members had defrauded them of an aggregate amount of
5,600
crore by fabricating documents and falsifying records pertaining to
warehouse receipts and contracts, which were not backed by any
underlying physical commodities. When the investors sought
delivery of commodities corresponding to their investments, the
borrowers failed to supply the same, as the actual stock of goods
available in the warehouses was significantly deficient.
Consequently, the ED attached several assets of a few corporates
under the PMLA while the Government of Maharashtra acted upon
an F.I.R filed against the 24 defaulters and attached properties of
the trading members, directors and sister concerns of NSEL under
the Maharashtra Protection of Interest of Depositors (in Financial
Establishments) Act, 1999 (MPID Act). On a petition filed by NSEL,
SC, vide order dated 04.05.2022, constituted a High-Powered
Committee (S.C. Committee) to execute decrees/awards passed
by different Courts across the country and consolidate proceedings
for hearing before it. During the course of the proceedings, the
following issues came up for consideration before the S.C.
Committee (1) Do secured creditors have priority over assets
attached under PMLA and MPID Act by virtue of SARFAESI Act,
2002 and RDB Act, 1993? (2) Are properties of judgment debtors
and garnishees attached under the MPID Act available for decree
execution despite the commencement of moratorium under section
14 of the Code? The S.C. Committee held that since the attached
properties are in nature of proceeds of crime under the PMLA Act
and the MPID Act, the secured creditors cannot claim priority over
the assets of the judgment debtors. Moreover, the S.C. Committee
23
INSOLVENCY AND BANKRUPTCY NEWS
held that properties which were attached under section 4 of the
MPID Act prior to imposition of the moratorium of the judgement
debtor or Garnishee (PG) under section 14 or section 96 of the
Code, such properties were not liable to be made part of insolvency
resolution process of the CD or PG, and could be available to the
S.C. Committee for recovery of money. However, as regards the
properties which were sought to be attached after the
commencement of moratorium, which were not yet attached under
SECTION Section 32

Untitled Section

section 4 of the MPID Act, the S.C. Committee concluded that the
decree holder would be entitled to pursue its claim as a FC in
accordance with the Code. The SC upheld the orders of the S.C.
Committee on the ground that the secured creditors have no priority
over assets attached under the MPID Act, since the assets of NSEL
do not qualify as “debt” under section 26E of the SARFAESI Act.
Moreover, the properties attached under MPID Act before the
moratorium imposed under the Code vests with the competent
authority established under the MPID Act. SC concluded that,
irrespective of the enactment of the SARFAESI Act and the RDB
Act in the Central List (List-I) of the Indian Constitution and having
been enacted by Parliament, they could not be permitted to override
the MPID Act, since it is validly enacted under the State List (List -
II) and shall amount to denuding the State of its legislative power to
enact and enforce legislation under Article 246 of the Constitution.
In addition to it, SC concluded that the overriding effect of section
238 of the Code shall not apply, since there is no repugnancy
between the Code and the MPID Act as required under Article 254
of the Constitution. SC, while upholding the decision of the S.C.
Committee, held that properties of the judgment debtors and
garnishees attached under the provisions of the MPID Act, would
be available for the execution of the decrees against the judgment
debtors by the S.C. Committee, despite the provision of moratorium
under section 14 of the Code.
Perfect Infraengineers Limited Vs. Technology Development
Board [SLP (C) No(s). 13015 of 2025]
Issue for consideration before Hon’ble Supreme Court was whether
admission order passed by AA against a CD can be directly
challenged before it under Article 136 of the Constitution, which
provides discretionary power to SC to grant special leave to appeal
against any judgment, decree, determination, sentence, or order
of any court or tribunal in India. SC while dismissing the appeal
filed by the CD held that the grievances regarding the admission of
a section 7 petition should be addressed through an appeal to the
NCLAT, not through a special leave petition under Article 136 of
the Constitution as the bar of limitation cannot be obviated or
circumvented by taking recourse of proceedings under Article 136
of the Constitution when a statutory appeal is available.
F.2 National Company Law Appellate Tribunal
Busy Bee Airways Private Limited Vs. Dinkar T.
Venkatasubramanian & Ors. [CA (AT) (Ins) No.124,175 & 244 of
2025]
Go Airlines (India) Private, (CD), a low-cost airline, filed a petition
for CIRP under section 10 of the Code, which was approved by the
AA.A resolution plan filed by Busy Bee Airways Private Limited
(PRA) was rejected by the CoC since it did not meet the eligibility
criteria to submit a resolution plan for the CD. Meanwhile, the aircraft
lessors approached Delhi HC seeking deregistration of the aircrafts
lying with the CD and permission to export them, which was
approved by the HC. As no viable resolution plans for the CD were
available, AA ordered liquidation of CD based on the approval of
CoC.In an appeal filed by the PRA, the issues before the NCLAT
were as follows: (1) Was the CoC’s decision to liquidate Go Airlines
under section 33(2) IBC valid? (2) Can the CoC authorize the
liquidator to sell the CD’s assets on a standalone basis, in a slump
sale, or in parcels without prioritizing a going concern sale? (3) Is
there an opportunity for a compromise or arrangement under section
230 of the Companies Act, 2013, during liquidation? The NCLAT
while disposing the appeal, upheld the liquidation of the CD as the
powers given to the CoC to take decision for liquidation is very
wide, which can be exercised immediately after constitution of the
CoC in consonance with section 33 (2) of the Code. It observed
that the CoC is vested with the authority to direct the liquidator to
sell the CD’s assets on a standalone basis, in a slump sale, or in
parcels without prioritizing a going concern sale. NCLAT further
observed no infirmity in the order of liquidation of, since the CoC
had explored the option of sale of the CD as a going concern under
regulation 32(e) of Liquidation Regulation and sale of the business
of the CD as a going concern under regulation 39 of the CIRP
Regulations, 2016, before directing the CD into liquidation. Lastly
it held that the PRA has the liberty to seek compromise or
arrangement under section 230 of the Companies Act, 2013 or
regulation 2B of the Liquidation Regulations within the period of 90
days from order of liquidation.
Max Publicity & Communication Private Limited Vs. Enviro
Home Solutions Private Limited [CA (AT) (Ins) No. 456 of 2025]
Suumaya Group (third party) had approached Max Publicity &
Communication Private Limited (CD) to coordinate between Veda
(third party) and vendors for supply of essential commodities to
Veda.Veda supplied those essential commodities to the
Government of India as an initiative under their Corporate Social
Responsibility (CSR). The CD issued a letter of intent and purchase
order to Enviro Home Solutions Private Ltd (vendor and OC) for
supplying raw materials to the CD, who in turn will deliver it to Veda.
The CD had paid a partial amount to the OC for the amount due.
Later, the CD alleged fraud by the OC by fabricating the lorry receipts
and while reversing the payments pending, filed a criminal complaint
against the OC before the Commissioner of Police, Gurgaon.
Consequently, the OC filed a section 9 petition under the Code to
initiate CIRP against the CD. The AA, vide order dated 21.01.2025,
found no proof of delivery by the OC to the CD and dismissed the
petition filed by the OC. AA observed that a fraud as being committed
by the CD and directed the Income Tax Department, EOW and
SFIO to conduct investigation into the entire transactions relating
to CSR obligations of Veda. On appeal filed by the CD, the issues
before the NCLAT were as follows (1) whether AA had the jurisdiction
to direct statutory authorities for investigation while dismissing the
insolvency petition. (2) whether the CD’s actions warranted
investigation for alleged fraud in CSR transactions with Veda and
Suumaya.The NCLAT observed that the AA, while exercising
jurisdiction under section 9 of the IBC also exercised its jurisdiction
under the Companies Act, 2013. It noted that the AA, in exercise of
powers under section 213 of the Companies Act, 2013, can direct
for investigation provided that a reasonable opportunity is afforded
to the parties concerned. NCLAT while disposing the appeal held
that the reference under section 212 to carry out any investigation
of a company’s affairs by SFIO can be made only in accordance
with the statutory provisions of Section 212 of the Companies Act
INSOLVENCY AND BANKRUPTCY NEWS
24
and the AA, while exercising jurisdiction under the IBC it cannot
issue any direction to SFIO for carrying out investigation.
Asha Basantilal Surana Vs. State Bank of India & Ors. [I.A. No.
334 of 2025 in CA (AT) (Ins) No. 84 of 2025]
M/s. Surana Metacast (India) Private Private (CD) availed credit
facilities from State Bank of India (FC), which were secured by a
personal guarantee of Mrs. Asha Basantilal Surana (PG). As the
CD’s loan was declared as NPA, the FC served a demand notice
under section 13(2) of the SARFAESI Act, 2002, on the CD and on
the PG. Subsequently, FC secured an order under section 14 of
the SARFAESI Act and issued a sale notice to take physical
possession of secured assets of the CD under the provisions of
the SARFAESI Act. Meanwhile, CIRP was initiated by the FC against
the CD. Thereafter, the PG filed an application under section 94(1)
of the IBC for initiating personal insolvency, which the AA rejected
on the ground that it was premature as no specific notice was issued
to invoke the guarantee. In appeal filed by the PG, the issue before
the NCLAT was whether the notice issued by the FC to PG under
SECTION Section 33

Untitled Section

section 13(2) notice provided sufficient cause for the PG to file an
application for personal insolvency under section 94(1) of the Code.
The NCLAT, while allowing the appeal, observed that Clause 7 of
the Guarantee Agreement requires that the Guarantors shall
forthwith on demand made by the Bank, deposit such sum or
security as the Bank may specify for the due fulfilment of their
obligations.The said clause does not require any particular mode
and manner of the demand notice. As such demand notice issued
against the PG demanding them to discharge its liabilities, the
guarantee stands invoked. NCLAT held that its judgment dated
05.01.2023 in Amanjyot Singh Vs. Navneet Kumar Jain RP
(Company Appeal (AT) (Insolvency) No.961 of 2022) cannot be
read to mean that this tribunal had held that the personal guarantee
could never be invoked by notice under section 13(2). The decision
in Amanjyot was with reference to the specific facts of that case. It
further held that for finding out as to whether a notice under section
13(2) invoked the personal guarantee to discharge PG’s liabilities
or not, the letters and words of the notice have to be looked into.
Lotus 300 Apartment Owners’ Association Vs. IndusInd Bank
Limited & Ors. [CA(AT) (Ins.) No. 1471 of 2022]
AA passed admission orders against Hacienda Projects Private
Limited, a developer of the real estate project, under section 7 on
an application filed by IndusInd Bank (FC). The said admission
order was challenged by the Lotus 300 Apartment Owners’
Association (Association), representing all 330 flats buyers in the
project inter alia on the ground that the project is near completion.
Issues for consideration before NCLAT was whether the AA’s order
admitting CD to CIRP could be set aside, allowing the association
to complete the project while keeping the CIRP in abeyance. NCLAT
observed that during the CIRP stage, the RP has to perform his
role in accordance with provisions of the Code and Regulations
made thereunder. In terms of provisions of the Code and
Regulations thereunder, the CoC shall constitute primarily of all
the homebuyers as a class who are stated to be predominant with
98% voting in the composition of CoC, with a FC having remaining
voting share. It is for CoC to decide the future course of action and
RP is supposed to act under the advice and directions to the CoC.
Considering the fact that 99% of the project has been completed,
the NCLAT directed that the remaining work shall be completed by
the CoC through RP.
Wakai Hospitality Private Limited Vs. Palak Desai & Anr. [CA
(AT) (Ins) No. 524 of 2024]
The appeal was filed by a licensee occupying a commercial property
owned by the CD undergoing insolvency under the Code. The
licensee challenged the order of AA which had directed it to vacate
the premises and pay outstanding license fees to the CD. The
appellant brought to the notice of AA that it had entered in to Leave
and License Agreement (LLA) with the former management of CD
prior to the insolvency commencement date, on the condition of
adjusting significant renovation costs against future license fees.
The RP of the CD, upon noticing the non-payment of licensee, had
terminated the LLA and sought possession of the property. The
issues before the NCLAT were (i) whether the AA has jurisdiction
to adjudicate upon eviction and recovery of rent, which is typically
a matter for civil courts; and (ii) whether an RP has the authority to
terminate a contract during the moratorium period under section
14 of the IBC. NCLAT, while dismissing the appeal, held that the
AA possesses the necessary jurisdiction to decide on matters
pertaining to the assets of the CD. It ruled that an asset owned by
the CD, even if in possession of a third party, must be handed over
to the RP to ensure maximization of its value. On the second issue,
the NCLAT clarified that the moratorium under section 14 is a
protective shield for the CD against third-party actions and cannot
be used as a sword by a defaulting third party to continue its breach
of contract. The RP has a duty to protect the CD’s assets, which
includes terminating agreements that are detrimental to the
insolvency estate.
Vinod Singh Vs. Chandra Prakash Jain & Ors. [CA (AT) (Ins)
Nos.800 & 801 of 2025]
The shareholders of the corporate person (CP) passed a resolution
to replace the existing liquidator with a new one in a voluntary
liquidation process. The outgoing liquidator challenged this decision
through an IA before the AA who had directed the parties to maintain
“status quo” regarding the position of the liquidator, effectively halting
the replacement. Subsequently, the AA passed another order de-
reserving its final order on the matter. The Director of CP challenged
both these orders before the NCLAT. The issue before the NCLAT
was whether the AA has the jurisdiction to interfere with the
commercial decision of a corporate person to replace its liquidator
during a voluntary liquidation process under section 59 of the IBC,
and consequently, whether its order to maintain “ status quo” was
legally tenable. The NCLAT, while allowing the appeal, held that
the process for replacement of a liquidator in a voluntary liquidation
of a solvent company is governed by a regime entirely different
from a liquidation following a CIRP . It clarified that the power to
appoint and replace a liquidator “ wherever required ” rests
exclusively with the corporate person by way of passing a resolution,
and no approval from the AA is necessary and there is no need for
the Director and Shareholder of the CD to communicate any reason
for removal of a liquidator. The NCLAT ruled that the AA’s statusquo
order was a “transgression of jurisdiction” and was passed in
violation of the statutory framework of the IBC. The NCLAT vacated
the statusquo order and directed the outgoing liquidator to hand
over all records as required by the regulations to the new liquidator
for proceeding with the process.
25
INSOLVENCY AND BANKRUPTCY NEWS
F.3 National Company Law Tribunal
Encore Asset Reconstruction Company Private Limited Vs. M/
s New Tech Imports Private Limited [C.P. (IB) No. 823(ND)/2022]
Owing to the repeated defaults by New Tech Imports Private Limited
(CD) in repayment of the outstanding dues, the FC formally declared
the account of the CD as Non-Performing Asset (NPA) and sent a
statutory recall notice under the section 13(2) of the SARFAESI
Act, 2002 to the CD and the Guarantors. During the course of
proceedings before DRT, the FC filed a petition against the CD to
initiate CIRP under section 7 of the Code. DRT, vide order dated
16.11.2024, held that classification of the CD’s account as NPA
was illegal since the date of classification of CD’s account as NPA
is inconsistent with FC’s own communication and the FC failed to
comply with the RBI guidelines while classifying the account of the
CD as NPA. The issues before the AA were as follows (1) whether
the classification of the account of the CD as NPA can be considered
as ‘default’ for the purpose of proceedings under the Code, (2)
whether an order passed by the DRT in setting aside the
classification of the account as a NPA, has any bearing on the
present insolvency proceedings under the Code. AA, while
disposing the application held that while the classification of an
account as NPA may be indicative of financial distress, mere
classification of an account as NPA does not ipso facto translate
as ‘default’ under section 7 of the Code, since the Code mandates
that the existence of a financial debt and its non-payment must be
independently established by the FC. While examining the
overriding effect of the Code over the SARFAESI Act under which
the DRT exercises jurisdiction, the AA concluded that an order of
the DRT setting aside NPA classification does not negate the
existence of financial debt or the occurrence of default. AA, while
initiating CIRP of the CD, held that the DRT’s jurisdiction is limited
to determining whether the lender followed the correct procedure
under SARFAESI, and it does not extend to making findings on
default under the Code, which is the sole domain of the AA.
Consortium of Karishma Jain, Jupiter City Developers (I)
Limited, and Adwaita Navigations Private Limited, Successful
Resolution Applicant of XL Energy Limited Vs. National Stock
Exchange of India Limited & Ors [I.A (IBC) No. 1726 of 2024 in
C.P (IB) No.16/7/HDB/2023]
AA, vide order dated 27.03.2023, initiated CIRP against XL Energy
Limited (CD). The resolution plan, as submitted by the consortium
of Ms. Karishma Jain (SRA), provided for relisting of CD’s equity
shares, since they were compulsorily delisted from the stock
exchanges for a period of ten years due to violations under the
SEBI (Delisting of Equity Shares) Regulations, 2009. As proposed
and approved by the AA, the SRA requested the NSE, BSE, CDSL,
and NSDL to relist the CD’s equity shares. However, the NSE
rejected the relisting of CD’s equity shares under regulation 40(1)(b)
of SEBI Delisting Regulations, 2021. Moreover, CDSL and NSDL
did not activate the CD’s credentials required for implementation
of the resolution plan, which hindered the allocation of new shares
and updation of the new shareholding structure. The issues before
the AA were as follows: - (1) whether the resolution plan binds
NSEL to relist CD’s equity shares? (2) whether prior offences of
the erstwhile management of the CD are extinguished post-approval
of the plan. (3) whether IBC overrides SEBI’s Delisting Regulations?
AA held that the approved resolution plan binds all stakeholders,
including NSE and BSE, under section 31(1) of the Code and neither
can raise any demand, condition, or requirement that is inconsistent
with or beyond the scope of the said plan. Moreover, AA upheld its
jurisdiction to direct relisting or on matters governed by SEBI
Regulations.AA concluded that given the overriding effect of section
238 of the Code, all past dues, offences and liabilities of the CD
stand extinguished by virtue of section 32 A of the Code and
accordingly, allowed the relisting of CD’s equity shares.
Goyal Tea Agencies Private Limited Vs. Shakti Bhog Snacks
Limited.[IA-3695-2023 in CP (IB) No. 1713 of 2019]
An application under section 54 of Code was filed by RP of CD-
Shakti Bhog Snacks Limited (CD) seeking dissolution of CD as
there was no scope for revival of CD. Apart from office of the CD
which was found sealed by the ED and a single bank account with
a negligible balance of Rs. 3701.81, there was no other asset. ED,
which was made party at later stage, opposed such application for
dissolution on the grounds that CD is a group company of Shakti
Bhog Foods Limited (SBFL), which was under prosecution for
default of Rs. 3,269 crore loan and large-scale money laundering.
According to the ED, SBSL had actively assisted SBFL in laundering
proceeds of crime by issuing bogus invoices, transferring funds to
shell companies, and layering illicit funds to project them as
legitimate revenue. Dissolution of CD would terminate the legal
existence of SBSL, which would frustrate the ongoing criminal
prosecution under PMLA. Considering the nature of proceedings,
AA observed that that IBC cannot be used to override the PMLA or
frustrate lawful investigations and attachments made under it. AA
while dismissing section 54 application observed that “It is not the
quantum but the character of the proceedings that is determinative.
The IBC cannot be used as a mechanism to frustrate or sidestep
the legitimate process of law under the PMLA.”
G.Building Ecosystem
G.1 IP Workshops
IBBI has been organising workshops for registered IPs with the
aim to deliver specialised and deep level learning through
a classroom, non-residential mode. It organised several Workshops
for the IPs during the quarter through online mode. The details of
the workshops conducted till June 30, 2025, is given in Table 34.
Table 34: Capacity Building Programmes for IPs till
June 30, 2025
Year / Period Workshops Webinars Roundtables Trainings Total
2016 - 17 1 - 8 - 9
2017 - 18 6 - 44 - 50
2018 - 19 7 - 22 - 29
2019 - 20 15 1 22 - 38
2020 - 21 9 29 18 2 58
2021 - 22 14 21 12 3 50
2022 - 23 18 6 6 6 36
2023 - 24 29 17 5 1 52
2024 - 25 22 3 2 1 28
Apr-Jun, 2025 3 - - - 3
Total 124 77 139 13 353
INSOLVENCY AND BANKRUPTCY NEWS
26
Online IP Workshop
The IBBI organised a Workshop for IPs on June 16, 2025 through
online mode focusing on building and strengthening capacity of IPs
and to make them aware of their responsibilities under the Code. The
Workshop was inaugurated by Mr. Ravinder Maini, ED, IBBI by delivery
of opening remarks. The expert faculty for the sessions included Ms.
Namisha Singh, Manager, IBBI and CA Vikram Kumar, IP .
Online IP Workshop, on June 16, 2025
IP Workshop in Chandigarh and Kochi
The IBBI organised a workshop for IPs in Chandigarh and Kochi
on April 30, 2025, and June 20, 2025 respectively. The workshops
were inaugurated by Mr. Ravinder Maini, ED, IBBI by delivery of
opening remarks. The expert faculty for the workshops included
Mr.Keshav Kumar Giridhari, DGM, IBBI, Ms. Namisha Singh,
Manager, IBBI, Mr. Sandeep Goel, IP and CMA Mr. Sankar P.
Panicker, IP .
IP Workshop, Chandigarh, April 30, 2025
IP Workshop, Kochi, June 20, 2025
G.2 Advocacy and Awareness
Capacity Building Workshop for the Officers of
Income Tax
The Insolvency and Bankruptcy Board of India (IBBI) conducted a
comprehensive capacity-building workshop for the officers stationed
at CCIT, New Delhi, on 25
th June 2025. The workshop aimed to
enhance the professional expertise, operational efficiency, and
domain-specific knowledge of the participants, fostering a deeper
understanding of insolvency and bankruptcy processes. This
initiative reflects IBBI’s commitment to promoting excellence and
continuous learning among its stakeholders.
Capacity Building Workshop at CCIT, New Delhi, June 25, 2025
G.3 Other Programmes
Senior officers of IBBI participated as guests and faculty in several
programmes during the quarter, the details of which are presented
in Table 35.
Table 35: Participation of Senior Officers in Programmes
Sl.Date Organiser Subject Participation
No.
1 10.05.2025 Confederation of CII Insolvency & Mr. Jithesh John,
Indian Industry Bankruptcy Code Executive Director,
Conclave, ITC Sonar, IBBI
Kolkata
2 25.05.2025 IPA ICMAI Session on Mr. Shiv Anant
Opportunities for Shanker, CGM
CMAs in the
Evolving IBC
Ecosphere in
National CMA
Convention
27
INSOLVENCY AND BANKRUPTCY NEWS
List of Abbreviations
AA Adjudicating Authority
AFA Authorisation for Assignment
AR Authorised Representative
BIFR Board for Industrial and Financial Reconstruction
BSE Bombay Stock Exchange
BT/BTs Bankruptcy Trustee/Trustees
CA Chartered Accountants
CD Corporate Debtor
CDSL Central Depository Services (India) Limited
CEO Chief Executive Officer
CIRP Corporate Insolvency Resolution Process
CIRP Regulations IBBI (Insolvency Resolution Process for Corporate Persons)
Regulations, 2016
CMA Cost and Management Accountants
CoC Committee of Creditors
CPE Continuing Professional Education
CPGRAMS Centralised Public Grievance Redress and Monitoring System
DRP Debt Realignment Plan
DRT Debt Recovery Tribunal
CS Company Secretary
CSR Corporate Social Responsibility
ED Executive Director
ED Enforcement Directorate
EOW Economic Offences Wing
FC/FCs Financial Creditor / Creditors
FIR First Information Report
FiSP/FiSPs Financial Service Provider/ Financial Service Providers
HC High Court
IBBI / Board Insolvency and Bankruptcy Board of India
IBC / Code Insolvency and Bankruptcy Code, 2016
ICAI Institute of Chartered Accountants of India
ICAI RVO ICAI Registered Valuers Organisation
ICD Insolvency Commencement Date
ICLS Indian Corporate Law Service
ICMAI Institute of Cost and Management Accountants of India
ICSI Institute of Company Secretaries of India
ICSI IIP ICSI Institute of Insolvency Professionals
IIIP ICAI Indian Institute of Insolvency Professionals of ICAI
IIVC Indonesia International Valuation Conference
IIM Indian Institute of Management
IP/IPs Insolvency Professional/ Professionals
IPA/IPAs Insolvency Professional Agency/ Agencies
IPA ICAI Insolvency Professional Agency of Institute of Cost
Accountants of India
IPE/IPEs Insolvency Professional Entity/Entities
IRP/IRPs Interim Resolution Professional/Professionals
IVSC International Valuation Standards Council.
ITD Income Tax Department
IU/IUs Information Utility/Utilities
LCD Liquidation Commencement Date
Liquidation Regulations IBBI (Liquidation Process) Regulations, 2016
LLA Leave and License Agreement
MCA Ministry of Corporate Affairs
MD Managing Director
MPID Act Maharashtra Protection of Interest of Depositors (in Financial
Establishments) Act
MSME Micro, Small and Medium Enterprise
NCLAT National Company Law Appellate Tribunal
NCLT National Company Law Tribunal
NeSL National e- Governance Services Limited
NI Act The Negotiable Instruments Act
NITI Aayog National Institution for Transforming India
NPA Non-Performing Asset
NSDL National Securities Depository Limited
NSE National Stock Exchange of India Limited
NSEL National Spot Exchange Limited
OC/OCs Operational Creditor/ Creditors
Panel Guidelines Insolvency Professionals to act as Interim Resolution
Professionals, Liquidators, Resolution Professionals and
Bankruptcy Trustees (Recommendation) Guidelines, 2024
PAO Provisional attachment order
PG/PGs Personal Guarantor/Guarantors
PGIP Post Graduate Insolvency Programme
PIRP Personal Insolvency Resolution Process
PMLA The Prevention of Money Laundering Act, 2002
PMO Prime Minister’s Office
PPIRP Pre-Packaged Insolvency Resolution Process
PRA Prospective Resolution Applicant
RBI Reserve Bank of India
RDB Act, 1993 The Recovery of Debts and Bankruptcy Act, 1993
RERA Real Estate Regulatory Authority
RoD Record of Default
RP/RPs Resolution Professional/Professionals
RV/RVs Registered Valuer/Registered Valuers
RVO/RVOs Registered Valuer Organisation/Registered Valuer
Organisations
SARFAESI Act Securitisation and Reconstruction of Financial Assets and
Enforcement of Security Interest Act, 2002
SBFL Shakti Bhog Foods Limited
SBSL Shakti Bhog Snacks Limited
SC Supreme Court of India
SCN Show Cause Notice
SCRA Act Securities Contracts (Regulation) Act, 1956
SEBI Securities and Exchange Board of India
SFIO Serious Fraud Investigation Office
SLP Special Leave Petition
SRA Successful Resolution Applicant
Valuation Rules The Companies (Registered Valuers and Valuation) Rules,
2017
WP Writ Petition
WTM Whole Time Member
SECTION Section 4

Untitled Section

1.CIRPs in 39 matters which yielded resolution plans and were reported earlier in this table have since moved into liquidation. The CIRPs have restarted
in 29 cases and CIRPs in 3 matters, where liquidation orders were passed earlier, have yielded resolution plans.
2.. During the quarter, there are 08 CIRPs where the realisable value was less than the liquidation value of the CD. While real isable value is significantly
influenced by the value of asset of the CD while entering the resolution process and time taken for resolution, it is also the outcome of a market determined
price discovery process and commercial wisdom of the CoC.
* Based on 1135 cases where fair value has been estimated.
NA: Not available
owed Rs. 10.46 lakh crore to the creditors. Till June, 2025,
realisation by the claimants under resolution plans in comparison
to liquidation value is 178.17%, while the realisation by them in
comparison to their claims is 33.70%. These realisations are
exclusive of realisations that would arise from value of equity
holdings post-resolution, resolution of PGs to CDs, and from
disposal of applications for avoidance transactions. The details are
presented in Table 6.
Table 6: Details of resolution of large cases as on June 30,
2025
(Amount in Rs. lakh crore)
CIRP cases (Admitted Claims > ` 1,000 crore) Till Ma r Apr-June T otal as
2025 2025 on June
30, 2025
No.of Cases 172 5 177
Admitted Claims 10.24 0.22 10.46
Liquidation Value 1.95 0.03 1.98
Realisation by creditors 3.47 0.06 3.53
Realisation by creditors as % of 33.89 27.27 33.70
Admitted Claims
Realisation by creditors as % of 177.61 193.10 178.17
Liquidation Value
C.5.3 Resolution of FiSPs
CIRPs of four financial service providers (FiSPs) i.e. Dewan Housing
Finance Corporation Ltd., Srei Equipment Finance Limited, Srei
Infrastructure Finance Limited and Reliance Capital Limited have
yielded resolutions under the Code. The details of the resolutions
are presented in Table 7. CIRP in the matter of AVIOM India Housing
Finance Private Limited has been admitted vide order of AA dated
February 20, 2025.
Till June, 2025, the creditors have realised Rs. 3.96 lakh crore
under the resolution plans. The fair value and liquidation value of
the assets available with these CDs, when they entered the CIRP ,
was estimated at Rs. 3.50 lakh crore and Rs. 2.32 lakh crore,
respectively, as against the total claims of the creditors worth Rs.
12.15 lakh crore. The creditors have realised 170.84% of the
liquidation value and 94.89% of the fair value (based on 1135 cases
where fair value has been estimated). The haircut for creditors
relative to the fair value of assets was less than 6%, while relative
to their admitted claims is around 67%. Furthermore, this realisation
does not include the CIRP cost, and many probable future
realisations such as equity, realisation from corporate and personal
guarantees, funds infused into the CD including capital expenditure
by the resolution applicants, and recovery from avoidance
applications.
About 40% of the CIRPs (497 out of 1229 for which data are
available), which yielded resolution plans, were earlier with BIFR
and/or defunct. In these CDs, the claimants have realised 18.91%
of their admitted claims and 152.42% of liquidation value.
The remaining 60% of the CIRPs which yielded resolution plans,
were not defunct at the time of commencement of CIRP . In these
CDs, the claimants have realised 34.98% of their admitted claims
and 172.84% of liquidation value.
C.5.2 Resolution of Large Cases (Admitted Claims
>Rs. 1000 crore)
Of the 1258 CDs rescued under the Code as on June 30, 2025,
177 had admitted claims of more than Rs. 1,000 crore. The
realisable value of the assets available with these 177 CDs, when
they entered the CIRP , was only Rs. 1.98 lakh crore, though they
INSOLVENCY AND BANKRUPTCY NEWS
10
Table 7: Details of resolution plans approved for FiSPs
(Amount in Rs. crore)
Sl.Claims of Financial Creditors Dealt Under Resolution Resolution
Name of FiSP Amount Amount Realization Realisation Applicant
Admitted Realized as % of as % of
admitted Liquidation
claims value
1 Dewan Housing 87247.68 37167.00 42.60% 138.42% Piramal Capital
Finance & Housing
Corporation Ltd Finance Limited
2 Srei Equipment 33050.43 13784.76 42.12% 280.74% National Asset
Finance Limited Reconstruction
Company Ltd.
3 Srei Infrastructure
Finance Limited
4 Reliance Capital 26088.97 9661.00 37.03% 73.42% IndusInd
Ltd International
Holdings Ltd.
C.6 Withdrawals under Section 12A
Till June, 2025, a total of 1191 CIRPs have been withdrawn under
SECTION Section 5

Untitled Section

section 12A of the Code. The reasons for withdrawal and distribution
of claims in these CIRPs are presented in Figures 9 and 10. Almost
three-fourth of these CIRPs had claims of less than Rs. 10 crore.
Figure 9: Reasons for Withdrawal of CIRPs
C.7 Liquidation
C.7.1 Overall outcomes
Till FY 2024-25, a total of 2758 CIRPs had yielded orders for
liquidation, of which the final reports were submitted in 1374 cases.
During the quarter April- June, 2025 04 more CIRP were reported
as yielding orders for liquidation, pertaining to the prior period. 03
cases which had earlier ended in liquidation, has now been ordered
to be withdrawn/ closed. Further, 65 CIRPs ended in orders for
liquidation during the current quarter, taking the total CIRPs ending
in liquidation to 2824. Of these, final reports have been submitted
in 1439 cases.
Till June, 2025 2824 CIRPs have ended in liquidation. Of the 2824
CDs, 1439 CDs have been completely liquidated with submission
of final report. The overview of closed liquidation processes and
timeline of ongoing 1385 cases is presented in Table 8 and Figure
11 respectively. CD-wise details of liquidation processes closed
during this quarter are presented in Table 9.
Table 8: Mode of Closure of Liquidation Processes
Status of Liquidation Till Ma rch, April-June, Total as
2025 2025 on June 30,
2025
Initiated 2759 65 2824
Final Report submitted 1407 32 1439
Closed by Dissolution (A) 814 27 841
Closed by Going Concern Sale (B) 102 1 103
Closed by Compromise / Arrangement (C) 15 0 15
Ongoing processes 1352 33 1385
Total Closed cases (A+B+C) 931 28 959
Total Admitted Claims (In Rs. crore) 261203.13 1451.66 262654.79
Liquidation Value (In Rs. crore) 10535.75 34.9 10570.65
Total Realisation (In Rs. crore) 9572.57 35.51 9608.08
*This excludes 48 cases where liquidation order has been set aside by
NCLT / NCLAT / HC / SC.
Figure 10: Distribution of CIRPs Withdrawn (as per
Admitted Claims)
Figure 11: Timeline: Ongoing Liquidations
60 54
396
271
405
Full settlement
with the
applicant
Full settlement
with other
creditors
Agreement to
settle in future
Other settlements
with creditors
Others
11
INSOLVENCY AND BANKRUPTCY NEWS
Table 9: Details of closed Liquidations
(Amount in Rs. crore)
Sl.Name of the Corporate Person Date of Amount of Liquidation Sale Amoun t Date of Order
Order of Admitted Value Proceeds Distributed to of Dissolution/
Liquidation Claims Stakeholders Closure
Part A: Reported for Prior Period (Till March, 2025)
1 Anand Distilleries Pvt Ltd 11-08-2023 0.00 0.00 0.00 0.00 03-01-2024
2 Abhiraami Chemicals Limited 19-09-2022 2.96 0.06 0.06 0.02 09-05-2024
3 Sharan Hospitality Private Limited 22-11-2023 0.00 0.00 0.00 0.00 02-07-2024
4 Virtue Infra And Entertainment Private Limited 10-05-2022 0.00 0.00 0.00 0.00 11-07-2024
5 Topknit Processing Mill Private Limited 26-07-2023 25.29 8.79 0.19 0.00 24-07-2024
6 Mata Energy Limited 31-05-2024 0.00 0.00 0.00 0.00 06-08-2024
7 Earth Water Limited 03-01-2023 312.06 8.54 6.03 4.50 05-09-2024
8 Tirupur Plaza Hotel Private Limited 15-02-2023 12.89 11.68 3.00 2.45 18-12-2024
9 Deogiri Infrastructure Private Limited 05-10-2023 84.84 0.45 1.35 0.98 24-01-2025
10 Lakshmi Transcon Pvt. Ltd. 28-03-2024 24.17 4.91 7.44 4.67 14-02-2025
11 Saptarishi Hotels Private Limited 19-10-2022 5.79 0.00 0.67 0.36 07-03-2025
12 Ibridge Solutions Pvt Ltd 01-02-2024 0.00 0.00 0.08 0.00 27-03-2025
Part B: For April - June, 2025
1 Karan Processors Private Limited 26-11-2020 2.33 0.39 0.39 0.35 09-04-2025
2 Praveer Constructions Private Limited 27-09-2019 11.78 2.13 2.67 1.62 22-04-2025
3 Floram Shoes (India) Private Limited 27-01-2021 55.67 7.84 8.96 8.45 22-04-2025
4 Nirmal Cars Private Limited 29-02-2024 0.00 0.05 0.13 0.00 22-04-2025
5 Aam Sky Geospatial Solutions Private Limited 20-10-2023 1.37 0.03 0.01 0.00 23-04-2025
6 Minesh Prints Limited 15-09-2023 0.30 1.06 0.19 0.04 29-04-2025
7 Shree Gajanan Agro Farms Private Limited 17-03-2023 23.22 6.84 5.78 5.53 01-05-2025
8 Komorebi Exports Private Limited 05-02-2020 1.82 0.15 0.10 0.00 02-05-2025
9 Rahi Shipping (India) Private Limited 16-06-2022 17.15 3.05 3.05 2.85 02-05-2025
10 Sintex Oil And Gas Limited 06-12-2022 429.47 0.96 1.11 0.86 05-05-2025
11 Jeph Bev Private Limited 22-12-2023 0.00 0.00 0.23 0.00 05-05-2025
12 SPG Multi Trade Private Limited 04-12-2020 187.52 0.90 0.00 0.00 06-05-2025
13 Sri Parameswara Poultry Farm Private Limited 24-03-2022 0.00 0.00 0.84 0.00 08-05-2025
14 Elexir Distributors Private Limited 01-01-2024 25.69 0.20 0.39 0.02 08-05-2025
15 Suashish Capital Pvt Ltd 06-10-2023 0.00 0.00 0.00 0.00 22-05-2025
16 Dentorth India Private Limited 13-03-2024 0.00 0.13 0.14 0.00 27-05-2025
17 Moli Merchant Traders Private Limited 25-11-2022 19.54 0.00 0.00 0.00 29-05-2025
18 Nandanam Tiles And Sanitaries Private Limited 14-08-2024 0.00 0.00 0.00 0.00 03-06-2025
19 Richa Creation India Private Limited 09-04-2019 0.00 0.00 0.00 0.00 04-06-2025
20 Aethon Energy LLP 08-06-2022 0.09 0.59 0.00 0.00 05-06-2025
21 Tyson Retail Services Private Limited 22-12-2022 1.72 0.39 0.00 0.00 06-06-2025
22 BrightsunTechnocraft Private Limited 24-12-2020 0.00 0.01 0.01 0.00 09-06-2025
23 Mono Acriglass Industries Private Limited 01-08-2022 617.50 2.03 2.80 2.70 10-06-2025
24 Sangaman Chit Funds Private Limited 11-01-2022 4.93 2.14 2.18 2.02 12-06-2025
25 PN Steel Traders Private Limited 02-09-2024 0.00 0.00 0.00 0.00 16-06-2025
26 FR Tech Innovations Private Limited 04-03-2024 1.13 0.00 0.00 0.00 17-06-2025
27 Sonali Energees Pvt. Ltd. 03-03-2021 28.87 3.91 4.42 3.88 23-06-2025
28 Globalite Industries Private Limited 18-11-2020 21.54 2.11 2.11 0.00 30-06-2025
Note: ‘-’ means no value;
0 means an amount below two decimals
NA means Not Applicable
INSOLVENCY AND BANKRUPTCY NEWS
12
Around 78% of the CIRPs ending in liquidation (2144 out of 2747
for which data are available) were earlier with BIFR and/or defunct.
The economic value in most of these CDs had almost completely
eroded even before they were admitted into CIRP . These CDs had
assets, on average, valued at 6.13% of the outstanding debt
amount.
C.7.2 Reasons for liquidation
The AA passes an order for liquidation under four circumstances.
As on June, 2025, 2824 orders for commencement of liquidation
have been passed. The details of liquidation in these circumstances
are presented in Figure 12.
Figure 12: Reasons for Liquidations
C.7.3 Claims in liquidation process
Regulation 12 of the Liquidation Regulations requires the liquidator
to make a public announcement calling upon stakeholders to submit
their claims as on the liquidation commencement date (LCD), within
30 days from the LCD. The details of the claims admitted by the
liquidators in 2824 liquidations, for which data are available, are
presented in Table 10.
Table10: Claims in Liquidation Process
(Amount in Rs. crore)
Stakeholders Number of Amount of Liquidation Amount Amount
under Section Claimants Claims Value Realised Distributed
Admitted
1439 Liquidations where Final Report Submitted
52 91 10708.98 668.91 661.93 650.60
53 (1) (a) NA NA 2682.68
53 (1) (b) 11931 291785.53 11392.28
53 (1) (c) 10029 333.60 16.36
53 (1) (d) 2340 79530.75 16268.10 14631.11 293.09
53 (1) (e) 1733 22030.19 51.26
53 (1) (f) 25476 19756.01 172.14
53 (1) (g) 8 17.55 0
53 (1) (h) 279 2175.66 21.66
Total (A) 51887 426338.27 16937.01 15293.04# 15280.07
Ongoing 1385 Liquidations
53 (1) (a) NA NA
53 (1) (b) 39025 640857.52
53 (1) (c) 30452 1343.38
53 (1) (d) 11577 124893.62
53 (1) (e) 2601 32181.09 52670.72***
53 (1) (f) 1966668 86127.94
53 (1) (g) 50 563.83
53 (1) (h) 105545 2647.62
Total (B) 2155918 888615.00
Grand Total 2207805 1314953.27 69607.73
(A+B)
# Inclusive of unclaimed proceeds of Rs.12.97 crore under liquidation.
***Out of 1385 ongoing cases, liquidation value of only 1145 CDs is available.
Liquidation value of 740 CDs taken during liquidation process is
Rs.39,083.48 crore and liquidation value of rest of the 405 CDs captured
during CIRP is Rs.13,587 crore.
C.7.4 Sale as Going Concern
Till June 2025, 103 CDs were closed by sale as a going concern
under liquidation process. These 103 CDs had claims amounting
to Rs. 160545.81 crore, as against the liquidation value of
Rs.5673.68 crore. The liquidators in these cases realized Rs.
4678.92 crore and companies were rescued.
C.8 Voluntary Liquidation
C.8.1 Overview
A corporate person may initiate voluntary liquidation proceeding
if majority of the directors or designated partners of the corporate
person make a declaration to the effect that (i) the corporate
person has no debt or it will be able to pay its debts in full, from
the proceeds of the assets to be sold under the proposed
liquidation, and (ii) the corporate person is not being liquidated to
defraud any person.
Till March, 2025, 2211 corporate persons initiated voluntary
liquidation of which final reports were submitted in 1680 cases and
44 cases were withdrawn.
At the end of June, 2025, 2341 corporate persons initiated voluntary
liquidation, of which final reports have been submitted in 1746
cases.Further, 44 processes have been withdrawn by June 30,
SECTION Section 6

Untitled Section

2025.The details of commencement of voluntary liquidations are
presented in Table 11. The timeline of ongoing voluntary liquidations
is presented in Figure 13.
Not
Applicable
Not
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INSOLVENCY AND BANKRUPTCY NEWS
Table 11: Commencement of Voluntary Liquidations till June
30, 2025 (Number)
Period Liquidations Liquidations Liquidation closed by Liquidations
at the Commenced Withdrawal Final at the end
beginning Reports of period
Submitted
2017 – 18 0 184 0 11 173
2018 – 19 173 232 7 108 290
2019 – 20 290 273 1 170 392
2020 – 21 392 250 2 186 454
2021 – 22 454 303 3 259 495
2022 – 23 495 320 9 335 471
2023 – 24 471 336 12 340 455
2024 - 25 455 383 10 302 526
Apr – Jun, 2025 526 60 0 35 551
Total NA 2341 44 1746 551
Of the 2297 corporate persons that initiated voluntary liquidations
(excluding withdrawals) till June 30, 2025, the reasons for these
initiations are available for 2275 cases, which are presented in
Figure 14. Most of these corporate persons are small entities.
1441 of them have paid-up equity capital of less than or equal to
Rs.1 crore. Only 332 of them have paid-up capital exceeding
Rs.5 crore. The corporate persons, for which details are available,
have an aggregate paid-up capital of Rs. 16,735 crore (Table 12).
Figure 13: Timeline of ongoing Voluntary
Liquidations
Figure 14: Reasons for Voluntary Liquidation
Table 12: Details of Voluntary Liquidations (Excluding
Withdrawals)
Details of No. of Amount (in Rs. crore)
Liquid- Paid-up Assets Out- Amount Surplus
ations capital* standing paid to
debt creditors
Liquidations for which ** 1746 9913 12357 665 665 13179
Final Reports submitted
Ongoing Liquidations 551 6822 4452# ***
Total 2297 16735 16809 ***
Notes:
* Paid up capital is not available in case of eleven companies as they are
limited by guarantee companies where there exist no shareholders and
paid-up capital.
** Data of 20 Final Report cases is awaited.
*** For ongoing liquidations, data is not available
# Assets of 520 cases are available.
C.8.2 Dissolution orders in voluntary liquidation
It was reported in the last newsletter that dissolution orders were
passed in respect of 1208 voluntary liquidations. Dissolution orders
in respect of 10 more voluntary liquidations, which were issued
during the earlier period, were reported later. During the quarter
April - June, 2025, dissolutions orders in respect of 61 voluntary
liquidations were issued taking the total dissolutions to 1279. These
1279 corporate persons owed Rs. 541.23 crore to creditors and
through voluntary liquidation process, they were paid full amount.
Table 13: Realisations under Voluntary Liquidations (Amount in Rs. crore)
Sl Name of Corporate Person Date of Date of Realisation Amount Amount Liquidation Surplus
No.Commencement Dissolution of Assets due to paid to Expenses
Creditors Creditors
Part A: For Prior Period (Till March, 2025)
1 Topstar Projects Private Limited 09-01-2024 01-06-2024 1.74 0.00 0.00 0.04 1.70
2 Vulcan Estates Pvt.Ltd. 20-02-2023 05-06-2024 17.14 1.69 1.69 0.11 15.34
3 Ars Sales Private Limited 27-12-2023 23-07-2024 0.61 0.01 0.01 0.03 0.58
4 Krishna Residency Private Limited 29-12-2023 29-11-2024 2.53 0.00 0.00 0.09 2.44
5 Adil Infratech Private Limited 21-12-2024 02-01-2025 0.00 0.00 0.00 0.00 0.00
6 Premier Logic India Private Limited 21-12-2021 20-02-2025 0.40 0.10 0.10 0.16 0.14
7 Maverick Digital Tech Private Limited 01-08-2023 25-02-2025 13.71 0.00 0.00 0.07 13.64
8 Fairmoney Financial Services Private Limited 05-10-2023 04-03-2025 2.08 0.00 0.00 0.07 2.01
9 Nuvo Chryscapital Advisors Private Limited 23-10-2023 20-03-2025 1.46 0.00 0.00 0.04 1.42
10 Tech Ideas Computer Systems Private Limited 29-04-2024 26-03-2025 1.04 0.10 0.10 0.04 0.90
INSOLVENCY AND BANKRUPTCY NEWS
14
Part B: For Apr - June, 2025
1 Ashuji Distributors Private Limited 22-07-2019 01-04-2025 0.50 0.00 0.00 0.02 0.49
2 Vinked Cloths Private Limited 07-01-2023 02-04-2025 5.84 0.00 0.00 0.13 5.70
3 Ritchie Bros Auctioneers India Private Limited 13-02-2024 04-04-2025 0.15 0.00 0.00 0.15 0.00
4 B & C Textiles Private Limited 17-10-2023 07-04-2025 1.23 0.00 0.00 0.06 1.16
5 Zenfer Marketing Pvt Ltd 30-10-2024 07-04-2025 2.36 0.00 0.00 2.36 0.00
6 Indore Fire Bricks Pvt Ltd 07-12-2024 07-04-2025 0.60 0.00 0.00 0.60 0.00
7 Ras Polybuild Products Private Limited 22-08-2020 09-04-2025 1.10 0.00 0.00 0.06 1.03
8 Dafater Consultants Private Limited 06-06-2022 09-04-2025 0.46 0.00 0.00 0.09 0.38
9 Saltmines Technologies Private Limited 13-06-2022 09-04-2025 0.15 0.00 0.00 0.04 0.11
10 Innovium India Private Limited 17-03-2023 09-04-2025 0.64 0.00 0.00 0.14 0.50
11 Rwe Renewables India Private Limited 14-11-2024 09-04-2025 0.00 0.00 0.00 0.00 0.00
12 Shree Cement Foundation 06-12-2024 17-04-2025 0.00 0.00 0.00 0.00 0.00
13 Shree Cement East Bengal Foundation 06-12-2024 17-04-2025 0.00 0.00 0.00 0.00 0.00
14 Gravitate Ventures Private Limited 22-12-2023 22-04-2025 0.68 0.00 0.00 0.06 0.62
15 Erwin India Private Limited 06-03-2024 22-04-2025 0.16 0.00 0.00 0.16 0.00
16 Coinwealth Ventures India Private Limited 07-12-2023 24-04-2025 0.29 0.27 0.27 0.02 0.00
17 Garda Tech Private Limited 22-12-2023 24-04-2025 0.76 0.00 0.00 0.47 0.29
18 Gupta Polymers Pvt.Ltd. 16-09-2023 25-04-2025 5.16 0.01 0.01 0.10 5.05
19 Jovial Trading Company Private Limited 23-02-2024 25-04-2025 0.19 0.00 0.00 0.02 0.18
20 Magic Hospitalities Private Limited 27-02-2023 28-04-2025 40.51 0.00 0.00 0.10 40.41
21 Ca Media India Advisors Private Limited 07-01-2019 30-04-2025 2.50 0.00 0.00 0.26 2.24
22 Mueller Prost Shared Services Private Limited 24-07-2024 30-04-2025 0.00 0.00 0.00 0.00 0.00
23 SSG Advisors LLP 23-11-2024 30-04-2025 0.56 0.00 0.00 0.56 0.00
24 Ricoh Innovations Private Limited 29-06-2020 01-05-2025 10.06 0.00 0.00 1.71 8.35
25 Itapp Software Private Limited 28-11-2022 01-05-2025 7.33 0.13 0.13 3.52 3.68
26 Shri Chamundi Captive Energy Private Limited 26-08-2019 02-05-2025 6.41 1.50 1.50 0.18 4.73
27 Vikram Health Services Private Limited 10-01-2022 02-05-2025 16.09 0.00 0.00 2.22 13.87
28 Linear Technology Semiconductor India Private Limited 14-03-2023 02-05-2025 0.40 0.00 0.00 0.07 0.33
29 R And S Engineering India Pvt Ltd 20-09-2023 02-05-2025 3.78 0.19 0.19 0.07 3.52
30 NRTU Foundation 17-01-2024 06-05-2025 0.04 0.00 0.00 0.04 0.00
31 Hitachi Plant Technologies India Private Limited 19-09-2018 07-05-2025 8.04 0.82 0.82 3.95 3.26
32 King’S Worldwide India Centre 20-12-2022 07-05-2025 0.00 0.00 0.00 0.00 0.00
33 April International Marketing Services (India) Private Limited 29-12-2020 08-05-2025 2.27 0.10 0.10 0.12 2.05
34 Ritesh Polysters Limited 11-12-2023 08-05-2025 0.03 0.00 0.00 0.03 0.00
35 Indo Austrian Business Forum 20-08-2024 16-05-2025 0.01 0.00 0.00 0.01 0.00
36 Lampsat Motors Private Limited 28-09-2022 22-05-2025 77.93 0.00 0.00 0.40 77.53
37 Zipdial Mobile Solutions Private Limited 05-11-2020 23-05-2025 4.63 0.00 0.00 0.51 4.12
38 Tele Dna Communications Private Limited 13-10-2022 23-05-2025 23.96 23.88 23.88 0.08 0.00
39 Fomi Foundry & Metallurgy India Private Limited 20-02-2023 23-05-2025 0.11 0.00 0.00 0.11 0.00
40 Chainalytics Services Private Limited 14-03-2023 23-05-2025 13.42 0.00 0.00 0.63 12.79
41 Evernote Technologies India Private Limited 15-02-2024 23-05-2025 0.23 0.00 0.00 0.03 0.21
42 Cfld India Investment Private Limited 28-03-2020 26-05-2025 1.98 1.58 1.58 0.40 0.00
43 Bl Engineering Solutions Private Limited 15-07-2022 26-05-2025 0.36 0.00 0.00 0.05 0.31
44 KWH Motors Private Limited 29-09-2023 27-05-2025 5.21 0.00 0.00 0.18 5.03
45 Variman Fitness Private Limited 27-01-2024 27-05-2025 1.20 0.16 0.16 0.07 0.97
46 Mushin Infrastructure Private Limited 04-10-2017 28-05-2025 2.73 0.00 0.00 0.01 2.72
47 Super Tex Labels Private Limite 21-02-2022 28-05-2025 2.54 0.00 0.00 0.10 2.45
48 KKNT First Main Private Limited 30-09-2024 30-05-2025 0.02 0.00 0.00 0.02 0.00
49 Yogi Dyeing Limited 19-01-2022 04-06-2025 1.87 0.00 0.00 0.02 1.85
50 Fircosoft India Private Limited 30-01-2023 05-06-2025 0.97 0.00 0.00 0.33 0.64
51 BF Precision Private Limited 22-03-2024 05-06-2025 1.08 0.00 0.00 0.07 1.01
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INSOLVENCY AND BANKRUPTCY NEWS
52 Otsuka Foods India Private Limited 09-08-2022 09-06-2025 2.48 0.00 0.00 0.37 2.11
53 Skol Beer Manufacturing Company Limited 25-03-2023 09-06-2025 0.02 0.00 0.00 0.02 0.00
54 Nan Fang Enterprise (India) Private Limited 22-06-2024 09-06-2025 8.46 0.65 0.65 7.81 0.00
55 Greenfield Infotek Limited 11-12-2023 10-06-2025 0.03 0.00 0.00 0.03 0.00
56 Fawow Ventures Private Limited 17-09-2024 13-06-2025 1.42 0.00 0.00 0.04 1.38
57 Manisha Infotech Private Limited 06-02-2025 19-06-2025 2.17 0.00 0.00 0.01 2.15
58 VSK Holdings Private Limited 24-06-2020 26-06-2025 20.24 0.00 0.00 1.90 18.33
59 Statestreet Managed Accounts Services India Private Limited 06-02-2023 26-06-2025 1.50 0.00 0.00 0.34 1.17
60 Hibu India Private Limited 28-09-2021 30-06-2025 1.34 0.03 0.03 0.35 0.96
61 Newonn Advertising & Media Private Limited 23-09-2023 30-06-2025 0.18 0.00 0.00 0.18 0.00
Total (April-June, 2025) 294.39 29.33 29.33 31.40 233.67
Total (Till June, 2025) 14215.64 665.03 665.03 373.07 13179.16
Notes: ‘0’ means an amount below two decimals;
‘-’ means no value
# Data awaited
C.9 Corporate Liquidation Accounts
The Regulations require a Liquidator to deposit the amount of
unclaimed dividends, if any, and undistributed proceeds, if any, in
a liquidation process along with any income earned thereon into
the corporate liquidation account before he submits an application
for dissolution of the corporate person. It also provides a process
for a stakeholder to seek withdrawal from the said account. Similar
provisions exist for voluntary liquidation processes. The details
of these accounts at the end of June 2025 are presented in
Table 14.
Table 14: Corporate Liquidation Accounts as on June 30, 2025
(Amount in Rs.lakh)
Name of Account Opening Deposit Withdrawn Balance at
Balance during during the end of
the period the period the period
Corporate Liquidation Account
2019 – 20 0 476.26 0.21 476.05
2020 – 21 476.05 116.18 0 592.23
2021 – 22 592.23 25.93 4.84 613.32
2022 – 23 613.32 596.1 0 1209.42
2023 – 24 1209.42 777.37 9.26 1977.53
2024 - 25 1977.53 755.16 3.16 2729.53
Apr – Jun, 2025 2729.53 16.11 19.06 2726.58
Corporate Voluntary Liquidation Account
2019 – 20 0 109.7 0 109.7
2020 – 21 109.7 112.06 0 221.76
2021 – 22 221.76 127.94 0.03 349.67
2022 – 23 349.67 241.29 10.42 580.54
2023 – 24 580.54 265.49 39.02 807.01
2024 - 25 807.01 166.51 17.50 956.02
Apr – Jun, 2025 956.02 106.14 2.74 1059.42
C.10 Pre-Packaged Insolvency Resolution Process
The Central Government enacted the Insolvency and Bankruptcy
Code (Amendment) Act, 2021 on August 11, 2021 which was
deemed to have come into force on April 4, 2021 introducing the
Pre-packaged Insolvency Resolution Process (PPIRP) for corporate
MSMEs.On April 9, 2021, the Central Government notified the
Insolvency and Bankruptcy (Pre-packaged Insolvency Resolution
Process) Rules, 2021 prescribing the manner and form of making
application to initiate PPIRP and the IBBI notified the IBBI (Pre-
packaged Insolvency Resolution Process) Regulations, 2021. The
Regulations provide for manner of carrying out certain processes
and tasks under PPIRP . As per the information available with the
Board, 14 applications have been admitted as on June 30, 2025,
out of which one has been withdrawn and resolution plans has
been approved in nine cases i.e., Amrit India Limited, Sudal
Industries Limited, Shree Rajasthan Syntex Limited, Enn Tee
International Limited, GCCL Infrastructure and Projects Limited,
Mudraa Lifespaces Private Limited, Garodia Chemicals Limited,
Kvir Towers Private Limited and RG Residency Private Limited.
The details of the ongoing cases are in Table 15.
Table 15: List of ongoing cases for PPIRP as on June 30, 2025
Sl.Name of the CD Date of Name of the
admission NCLT Bench
SECTION Section 7

Untitled Section

1.Kethos Tiles Private Limited 04-01-24 Ahmedabad
SECTION Section 8

Untitled Section

2.Shreemati Fashions Private Limited 05-01-24 Kolkata
SECTION Section 9

Untitled Section

3.Kratos Energy & Infrastructure Limited 01-02-24 Mumbai