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Supreme Court of India 2021-03-26 allowed

Indus Biotech Private Limited vs Kotak India Venture (Offshore) Fund (earlier known as Kotak India Venture Limited) & Ors

Bench: 3 — S. A. Bobde, A. S. Bopanna, V. Ramasubramanian

In Brief

Indus Biotech Private Limited sought arbitration of disputes with venture capital investors regarding the conversion of preference shares into equity shares, with disagreement on the percentage entitlement (10% vs 30%). When investors invoked insolvency proceedings, the company sought to refer the dispute to arbitration. The Supreme Court held that the trigger point for an insolvency proceeding to become a non-arbitrable "action in rem" is the Adjudicating Authority's admission after finding default—not the mere filing of a petition. Before admission, where the amount disputed is still being negotiated, no default has occurred. The Court allowed the arbitration petition and appointed arbitrators to resolve the conversion formula dispute.

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Arbitration and Conciliation Act Insolvency and Bankruptcy Code NCLT Jurisdiction Arbitrability Actions in Rem Default Financial Debt Procedural Law Corporate Insolvency Resolution Process

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