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Supreme Court of India 2023-03-15 dismissed

AJAY KUMAR RADHEYSHYAM GOENKA vs TOURISM FINANCE CORPORATION OF INDIA LTD

Bench: 3 — Sanjay Kishan Kaul, Abhay S. Oka, J.B. Pardiwala

In Brief

In this case, the Supreme Court considered whether a company director could escape criminal prosecution under Section 138 of the Negotiable Instruments Act (relating to dishonoured cheques) after the company's debt was settled through a resolution plan under the Insolvency and Bankruptcy Code. The Court held that criminal proceedings against directors and signatories continue independently of the company's insolvency resolution. Section 138 proceedings are penal in nature, not civil recovery. While the company itself may be protected once new management takes over, directors remain personally liable under Section 141 of the NI Act. The Court dismissed the appeals and held that approval of a resolution plan does not extinguish the criminal liability of those responsible for the company's business at the time of the offence.

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Negotiable Instruments Act Insolvency and Bankruptcy Code Criminal Law Company Law Section 138 Prosecution Director Liability Resolution Plan Moratorium IBC and Criminal Proceedings

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