In Brief
The Supreme Court held that a successful Resolution Applicant cannot withdraw or modify its Resolution Plan after approval by the Committee of Creditors and submission to the Adjudicating Authority. The IBC framework is self-contained and does not permit such withdrawals—the absence of statutory provision is determinative. A CoC-approved Resolution Plan is not a pure contract but a creature of the IBC whose binding effect arises from statute. Common law remedies like frustration are inapplicable. Strict timelines and predictability are essential to prevent asset depreciation. The Court dismissed appeals by Ebix and Seroco seeking withdrawal/modification, while granting one-time relief under Article 142 to Kundan Care to renegotiate with its CoC after a PPA dispute was resolved. Judicial restraint must be exercised to avoid undermining the IBC's objectives."
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