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Supreme Court of India 2026-02-24 dismissed

S. Rajendran vs The Deputy Commissioner of Income Tax (Benami Prohibition) & Ors

Bench: 2 — Pamidighantam Sri Narasimha, Atul S. Chandurkar

In Brief

A corporate debtor in liquidation sought to challenge property attachment orders under the Benami Transactions (Prohibition) Act, 1988 before insolvency forums under the Insolvency and Bankruptcy Code. The Supreme Court held that challenges to benami attachment orders must be pursued exclusively within the Benami Act's statutory framework, not through insolvency proceedings. The Court found the Benami Act constitutes a self-contained regime with its own adjudicatory authorities and appellate mechanisms. The insolvency moratorium does not override benami confiscation proceedings as sovereign public-interest actions. Property attached as benami does not form part of the liquidation estate. The Court dismissed the appeals, affirming lower tribunal decisions.

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Insolvency and Bankruptcy Code Benami Transactions (Prohibition) Act Corporate Insolvency Resolution Process Liquidation Attachment of Property Statutory Interpretation Conflict of Statutes Jurisdiction and Competence Public Law Adjudication

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