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Supreme Court of India 2021-12-17 allowed

NGAITLANG DHAR vs PANNA PRAGATI INFRASTRUCTURE PRIVATE LIMITED & ORS

Bench: 2 — L. Nageswara Rao, B.R. Gavai

In Brief

Ngaitlang Dhar, the successful bidder in a Corporate Insolvency Resolution Process, appealed against an NCLAT decision that had quashed the Committee of Creditors' approval of his Resolution Plan. The competing bidder, PPIPL, had sought to submit a revised bid after the CoC meeting but was denied further time due to strict adherence to the IBC's statutory 180-day deadline. The Supreme Court held that the CoC followed fair and transparent procedures, affording equal opportunity to all bidders. The Court confirmed that the 'commercial wisdom' of the CoC is protected from judicial review except on limited statutory grounds. No material irregularity was found in the procedure. The Court emphasised that adherence to IBC timelines is a legitimate consideration in CoC decisions. The appeals were allowed, the NCLAT order was quashed, and the CoC's approval of Ngaitlang Dhar's Resolution Plan was upheld.

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Insolvency and Bankruptcy Corporate Insolvency Resolution Process Committee of Creditors Resolution Professional Commercial Wisdom Judicial Review Material Irregularity

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