1 INSOLVENCY AND BANKRUPTCY NEWS CONTENTS FROM CHAIRPERSON’S DESK .................................................................................................................................................................. 2 INSOLVENCY AND BANKRUPTCY CODE (AMENDMENT) ACT, 2026 ........................................................................................................ 3 A. IBBI Updates ................................................................................................................................................................................. 6 A.1 Key Events ........................................................................................................................................................................... 6 A.2 Reports ................................................................................................................................................................................ 7 A.3 Human Resources ............................................................................................................................................................ 10 A.4 Employee Trainings and Workshops ............................................................................................................................... 10 B. Legal and Regulatory Framework .............................................................................................................................................. 10 B.1 Central Government .......................................................................................................................................................... 10 B.2 Regulations ....................................................................................................................................................................... 10 B.3 Circulars ............................................................................................................................................................................ 11 B.4 Invitation of public comments ............................................................................................................................................ 12 C. Corporate Processes .................................................................................................................................................................. 12 C.1 Overview ............................................................................................................................................................................. 12 C.2 Stakeholder-wise initiation of CIRP ................................................................................................................................... 13 C.3 Timelines ........................................................................................................................................................................... 14 C.3.1 For Concluded Processes ....................................................................................................................................... 14 C.3.2 For Ongoing CIRPs .................................................................................................................................................. 14 C.4 Resolution Plans ............................................................................................................................................................... 14 C.4.1 Overall outcomes ..................................................................................................................................................... 14 C.4.2 Resolution of Large Cases (Admitted Claims > Rs. 1000 crore) ........................................................................... 16 C.4.3 Resolution of FiSPs ................................................................................................................................................. 16 C.5 Withdrawals under Section 12A ........................................................................................................................................ 17 C.6 Liquidation ......................................................................................................................................................................... 17 C.6.1 Overall outcomes ..................................................................................................................................................... 17 C.6.2 Reasons for liquidation ........................................................................................................................................... 19 C.6.3 Claims in liquidation process.................................................................................................................................. 19 C.6.4 Sale as Going Concern ........................................................................................................................................... 20 C.7 Voluntary Liquidation.......................................................................................................................................................... 20 C.7.1 Overview ................................................................................................................................................................... 20 C.7.2 Dissolution orders in voluntary liquidation .............................................................................................................. 21 C.8 Corporate Liquidation Accounts ........................................................................................................................................ 23 C.9 Pre-Packaged Insolvency Resolution Process ................................................................................................................ 23 C. 10 Avoidance Transactions .................................................................................................................................................... 23 D. Individual Processes ................................................................................................................................................................... 23 D.1 Insolvency Resolution Process ......................................................................................................................................... 23 D.2 Bankruptcy Process ........................................................................................................................................................... 24 E. Service Providers ........................................................................................................................................................................ 24 E.1 Insolvency Professionals .................................................................................................................................................. 24 E.2 Replacement of IRP with RP ............................................................................................................................................. 25 E.3 Insolvency Professional Entities ....................................................................................................................................... 25 E.4 Insolvency Professional Agencies..................................................................................................................................... 26 E.5 Information Utility ............................................................................................................................................................... 26 E.6 Registered Valuer Organisations ...................................................................................................................................... 26 E.7 Complaints and Grievances.............................................................................................................................................. 28 E.8 Examinations ..................................................................................................................................................................... 28 E.8.1 Limited Insolvency Examination............................................................................................................................... 28 E.8.2 Valuation Examinations ............................................................................................................................................ 28 E.9 Disciplinary Orders ............................................................................................................................................................ 29 F. Orders................ ............................................................................................................................................................................ 29 F.1 Supreme Court .................................................................................................................................................................. 29 F.2 High Court .......................................................................................................................................................................... 32 F.3 National Company Law Appellate Tribunal ....................................................................................................................... 32 F.4 National Company Law Tribunal ....................................................................................................................................... 33 G. Building Ecosystem ..................................................................................................................................................................... 34 G.1 IP Workshops .................................................................................................................................................................... 34 G.2 Advocacy and Awareness .................................................................................................................................................. 34 G.3 Other Programmes ............................................................................................................................................................ 35 List of Abbreviations .............................................................................................................................................................................. 36

2 From Chairperson’s Desk Strengthening the Insolvency Framework through the IBC (Amendment) Act, 2026 The Insolvency and Bankruptcy Code, 2016 (IBC/ Code) has, over the past decade, emerged as a transformative reform in India’s financial and legal landscape. It has fundamentally changed the way distress is resolved, placing creditor rights, time-bound processes, and value maximisation at the centre of insolvency resolution. However, as with any evolving legal framework, experience in implementation revealed certain gaps, delays, and areas requiring clarity. The Insolvency and Bankruptcy Code (Amendment) Act, 2026, has been introduced to address these challenges. The Amendment Act contains 72 clauses in total. Each clause seeks to further strengthen the efficiency and efficacy of the insolvency resolution process. Overall, the objective is to make the Code more robust, predictable, and responsive to the needs of a dynamic economy. Some of the major amendments are set out below. 2. The process has been criticized for delays in admission of a CD into CIRP. The amendments now provide that in applications made by financial institutions, a record of default issued by the IU, would be counted as sufficient proof of default. This addresses a key bottleneck where admission of cases was often delayed due to prolonged litigation on evidence of default. By recognising IU records as reliable and structured evidence, the process becomes faster and more objective. 3. Another significant reform is the introduction of separate approval of the implementation of the resolution plan and the manner of distribution under the plan. The AA is now empowered to first approve the implementation part of a plan and subsequently approve the manner of distribution, on the recommendation of the CoC. This would lead to faster approval of the resolution plan. By separating these two aspects, the amendment provides certainty to resolution applicants, enabling them to take over and revive the business without waiting for all distribution- related issues to be resolved. This is expected to encourage greater investor participation and improve the success rate of resolution. 4. The amendments also expand the scope of resolution by allowing asset-wise or part resolution of the CD. This means that instead of requiring a single resolution plan for the entire entity, different assets or business units can be resolved separately. This is particularly useful in complex businesses or real estate projects, where different assets may attract different buyers. By enabling flexible resolution strategies, the amendment enhances value maximisation and reduces the likelihood of liquidation. 5. The Amendment Act introduces a significant reform by enabling transfer of assets of the guarantors as part of the insolvency resolution of the CD during CIRP. This is particularly useful in situations where assets of the CD and the guarantor are closely interlinked. For example, a factory may be owned by the CD, while the land on which it is constructed belongs to a guarantor of the CD. In such cases, resolving the CD in isolation becomes difficult, as a resolution applicant would require both the land and the factory to run the business effectively. The amendment now provides that where a creditor has already taken possession of such an asset by enforcing security interest, the asset may be transferred as part of the insolvency resolution process with prior approval of the CoC. 6. A crucial clarification has been introduced regarding the treatment of dissenting financial creditors. The law now clearly provides that dissenting creditors will receive at least the lower of the liquidation value or the amount receivable under the resolution plan if proceeds of such plan are distributed as per the priority waterfall under section 53. This ensures a minimum protected payout for dissenting creditors while not obstructing the approval of a feasible and viable resolution plan. 7. The amendments also now expressly provide that the interim moratorium will not apply where insolvency proceedings are initiated against a personal guarantor to a CD. This clarification addresses the ambiguity that had led to differing interpretations and litigation, especially in cases where creditors were restrained from proceeding against guarantors during the interim period. 8. The Amendment Act strengthens the framework for avoidance transactions by both expanding the look-back period and ensuring continuity of such proceedings. The relevant period for examining PUFE transactions is now counted from the initiation date (i.e., date of filing of application) rather than the insolvency commencement date, thereby capturing transactions undertaken in the interim period before admission which may have been used to siphon value. Further, it is expressly clarified that proceedings relating to avoidance transactions will continue even after the completion of CIRP or liquidation. This ensures that recovery actions are not defeated merely because the main insolvency process has concluded. 9. A notable change has been made in the liquidation framework by providing for supervision of the CoC during liquidation. Previously, the role of the CoC largely ended once liquidation commenced. By allowing the CoC to continue supervising the liquidation process, the amendment would lead to improved transparency and potentially enhance recoveries for creditors. 10. The amendments clarify that liabilities of personal guarantors remain unaffected by the resolution plan of the CD. This ensures that creditors can continue to pursue guarantors even after the CD is resolved. The provision strengthens creditor rights and prevents misuse of the resolution process as a means to escape liability through related parties. 11. The Amendment further strengthens regulatory governance. It provides for a statutory appeal to NCLAT against decisions of the Disciplinary Committee of the IBBI, decriminalizes section 235A replacing criminal liability with civil penalties imposed by the AA, and expands the regulation-making powers of the IBBI to effectively carry out the purposes of the Code. 12. A major structural reform introduced by the Amendment Act is the Creditor-Initiated Insolvency Resolution Process (CIIRP). Under this framework, a notified set of financial creditor(s) can initiate the process against a notified category of CDs without waiting for a formal admission by the AA at the outset. It largely follows a debtor-in-possession model with creditor oversight. The process culminates in a resolution plan approved by the creditors being submitted to the AA for final approval. By moving much of the process outside the court system and placing it firmly in the hands of creditors, CIIRP aims to reduce delays that often arise in the traditional CIRP. At the same time, appropriate safeguards such as approval of the resolution plan by AA, oversight by the CoC, section 29A disqualifications etc. remain in place to ensure that the process remains accountable. 13. Recognising the increasing complexity of modern corporate structures, the Amendment Act introduces a framework for group insolvency. This allows insolvency proceedings of interconnected companies within a group to be coordinated, including the possibility of a common adjudicating bench, coordination among CoCs and insolvency professionals, appointment of a common insolvency professional, and binding coordination agreements. A coordinated approach is expected to improve recoveries and enable more holistic resolution strategies. 14. Complementing this reform is the enabling provision for cross-border insolvency. The law now empowers the Central Government to frame rules for recognition of foreign proceedings, cooperation with foreign courts, and management of concurrent proceedings. In an increasingly globalised economy, where businesses operate across jurisdictions, this reform is essential to ensure effective resolution of cross-border insolvencies. It brings IBC closer to internationally accepted best practices and enhances investor confidence. 15. In conclusion, the IBC (Amendment) Act, 2026 represents a significant step forward in the evolution of India’s insolvency framework. By addressing practical challenges, reducing delays, and introducing new mechanisms, the amendments make the Code more resilient and future- ready. At its core, the reform continues to emphasise timely resolution, maximisation of value, and fairness to all stakeholders. As the ecosystem continues to mature, these changes are expected to further strengthen confidence in the insolvency regime and contribute to a more robust credit environment in the country. Ravi Mital

3 INSOLVENCY AND BANKRUPTCY CODE (AMENDMENT) ACT, 2026 The Insolvency and Bankruptcy Code (Amendment) Act, 2026 (hereinafter referred to as “Amendment Act”) received the assent of the President on 06 April, 2026. The Amendment Act has 72 clauses, introducing a wide range of amendments across the Code, aimed at improving processes, strengthening regulatory oversight, and enhancing the overall efficiency and effectiveness of the insolvency framework. Some of the important Amendments are set out below.

1. Clarity in Definitions
   

a. Security interest: The definition of “security interest” has been clarified to mean that a security interest exists only when the parties to an agreement intentionally create a right, title, interest, or claim over a property as security for a debt. It excludes situations where such a right arises automatically by operation of law without any explicit agreement between the parties. This clarification addresses disputes regarding the treatment of statutory dues as secured claims. b. Service provider: The term “service provider” has been introduced to include all categories of service providers such as IPs, IPAs, IUs, RVs, and other notified persons. This expands the regulatory scope of the Board and ensures that all key participants in the insolvency ecosystem are brought within a unified framework of oversight. c. Registered Valuer: The term “registered valuer” has been defined to clarify that a registered valuer shall carry the same meaning as assigned under Chapter XVII of the Companies Act, 2013. d. Avoidance Transactions: New definitions of “avoidance transaction” and “fraudulent or wrongful trading” have been inserted to consolidate references across the Code under the relevant sections - 43, 45, 49, 50 and 66. e. Initiation date: It has been clarified that where multiple applications for CIRP are pending against a CD, the “initiation date” shall be the date of filing of the first such application. This ensures uniformity in determining relevant timelines, particularly with respect to the look-back period for avoidance transactions. 2. Admission timeline and reliance on IU records The Amendment Act provides that the AA shall pass an order admitting or rejecting applications under sections 7, 9, and 10 within fourteen days of receipt of application. If the order is not passed within this period, reasons must be recorded in writing. It is further clarified that where a financial institution submits a record of default obtained from an IU along with the CIRP application, such record shall be treated as sufficient evidence for the AA to establish the existence of default. These amendments reduce delays at the admission stage and minimise disputes on proof of default. 3. Limitation on grounds for rejection of application It is clarified that once the AA is satisfied regarding the existence of default, completeness of the application, and absence of disciplinary proceedings against the proposed RP, the application must be admitted. No additional or extraneous grounds can be used for rejection. This ensures that admission is based on objective criteria and reduces scope for discretion. 4. Proposal to appoint IRP by CD In cases where the CIRP application is filed by the CD, the CD is no longer permitted to propose the name of the IRP for appointment. Instead, the AA shall refer the matter to the IBBI for recommending an IRP. This change ensures independence in appointment of IRP, impartial discharge of duties by the IRP and maintaining the confidence of creditors in the process. 5. Submission and verification of claims The provisions relating to submission of claims have been strengthened by empowering the IBBI to specify the manner in which claims are to be submitted by creditors. It is also clarified that the IRP is responsible not only for collating claims but also for verifying and determining their value. These changes standardise the claims process and improve accuracy. 6. Duty to cooperate with RP The scope of persons required to cooperate with the IRP/ RP has been expanded from “personnel” to “persons,” including promoters, management, and persons engaged with the CD through contracts. This ensures access to information and strengthens cooperation and assistance extended to the IRP/ RP during CIRP. 7. Withdrawal under section 12A The Amendment Act has placed restrictions on withdrawal of CIRP under section 12A. The amendment provides that an admitted CIRP application cannot be withdrawn before the constitution of CoC or after the RP has issued the first invitation for submission of resolution plans. Further, the RP is now empowered to file the withdrawal application, and the AA must dispose of such applications within thirty days, recording reasons for delay if this timeline is not met. These changes regulate withdrawal at defined stages and prevent misuse of the process. 8. Streamlining Resolution a. Expanded Scope of Resolution Plan: The definition of resolution plan has been expanded to explicitly include the sale of one or more assets of the CD through one or more resolution applicants. This enables asset-wise or part resolution, allowing different bidders to acquire specific business units or assets. The amendment facilitates flexible structuring of resolution plans, particularly in complex or diversified businesses. b. Plan Approval by CoC: An amendment has been made requiring that when the CoC approves a resolution plan, it must also record reasons for such approval. This introduces greater transparency and accountability in CoC decision- making. c. Two-step Approval of Resolution Plan: A new proviso has been inserted empowering the AA to first approve the implementation of a resolution plan and thereafter approve the manner of distribution under the plan. This can be done on an application by the RP, with approval of at least 66% voting share of the CoC. d. Time-bound Approval of Resolution Plan: The AA is required to approve or reject a resolution plan within thirty days of receipt. Reasons must be recorded for any delay. In case of a two-step plan, the AA must approve the manner of distribution within 30 days from approval of implementation. e. Rectification of Defects in Resolution Plan: Before rejecting a resolution plan, the AA may provide an opportunity to the CoC to rectify defects. This prevents rejection of plans on technical grounds and promotes resolution. f. Dissenting Financial Creditors’ Entitlement: The resolution plan must provide that dissenting financial creditors receive at least the lower of (i) the amount receivable in liquidation under section 53, or (ii) the amount receivable if distribution follows the priority under section 53. This ensures a minimum

4 protected payout for dissenting creditors while not obstructing the approval of a feasible and viable resolution plan. g. CCI Approval: The Amendment Act now provides that only the successful resolution applicant, where required, shall obtain prior approval of the Competition Commission of India (CCI) before the resolution plan is submitted to the AA for approval. The earlier requirement mandating prior approval from CCI for all prospective resolution applicants has been dispensed with. This amendment will reduce procedural delay, streamline the resolution process, and ease the regulatory burden on the CCI. h. Monitoring of Resolution Plan: The resolution plan is required to provide for a monitoring committee comprising of the RP or another IP, representatives of creditors, and the resolution applicant. This ensures proper supervision of implementation of plan. i. Clean Slate and Continuity of Licences:Upon approval of a resolution plan, all prior claims against the CD stand extinguished unless otherwise provided in the plan. Licences, permits, registrations, and approvals shall continue subject to compliance. j. Non-extinguishment of liability or proceedings against Promoters and Guarantors: It is clarified that the extinguishment of claims under the resolution plan does not affect liability or proceedings against promoters, management, guarantors, or persons jointly or severally liable with the CD. This preserves creditor rights against third parties. 9. Transfer of assets of guarantor A new provision now allows the transfer of assets of a personal guarantor or corporate guarantor during the CIRP of the CD. It provides that where a creditor has already taken possession of such an asset by enforcing security interest, the asset may be transferred as part of the insolvency resolution process with prior approval of the CoC. Further, once the asset is transferred under a resolution plan, all rights in relation to the asset vest in the transferee as if the transfer had been made by the owner. 10. Avoidance transactions a. Look-back period: The look-back period for preferential, undervalued, and extortionate transactions is revised to be calculated from the CIRP initiation date (date of filing of application) instead of the insolvency commencement date. This expands the scope to capture transactions occurring prior to admission. b. Fraudulent and Wrongful Trading: The scope of fraudulent and wrongful trading provisions has been clarified to apply during both CIRP and liquidation. This ensures continued accountability. c. Pursuance of Avoidance and Fraudulent and wrongful transactions during liquidation: The liquidator has been empowered to continue or initiate proceedings relating to avoidance transactions and fraudulent or wrongful trading. This strengthens enforcement powers during liquidation and ensures that recovery actions remain active. d. Continuation of Avoidance Proceedings: Proceedings relating to avoidance transactions and fraudulent or wrongful trading shall continue even after completion of CIRP or liquidation.Even after dissolution, proceedings relating to avoidance transactions shall continue. The CoC shall determine the manner of pursuing such proceedings and distribution of proceeds. e. Empowering creditors to file: Creditors (individually or jointly), members, or partners of the CD can directly approach the AA where the liquidator or RP has failed to report avoidance transactions. f. Inclusion of Related Party in proviso to Section 49: The amendment prevents the transactions wherein the asset of the CD is transferred to its related party, and consequently, such an asset is transferred from the related party to a third party, from being exempted as “transactions defrauding creditors”. This ensures that the transfer of the property through a related party does not gain protection under clause (a) of the proviso to section 49. 11. Streamlining liquidation a. Appointment of liquidator: Upon passing of liquidation order, the AA shall refer the matter to the Board for recommending an IP to act as liquidator other than the RP appointed during CIRP. Further, a new provision clarifies that the RP appointed during CIRP cannot be appointed or replaced as the liquidator for the same CD. This ensures separation of roles between resolution and liquidation stages. b. Moratorium during Liquidation: The AA may declare a moratorium during liquidation, applying relevant provisions of section 14. This restricts initiation or continuation of legal proceedings during liquidation. c. CoC Supervision during Liquidation: The CoC shall supervise the conduct of the liquidation process and may also choose to replace the liquidator with 66% voting share. This strengthens oversight and accountability even during liquidation. d. Direct Dissolution: The CoC may decide to directly dissolve the CD where there are no meaningful assets, without undergoing full liquidation. This avoids unnecessary delay and cost. e. Time-bound Liquidation: The liquidator must complete liquidation and apply for dissolution within 180 days, extendable by up to 90 days. The AA must pass the dissolution order within thirty days. This introduces timelines in liquidation. f. Omission of duplicate activities in CIRP and Liquidation: Provisions relating to fresh collation and verification of claims in liquidation have been omitted as these activities have already been completed during CIRP. The claims collated during the CIRP will be maintained and updated by the liquidator during the liquidation process.Similarly, sections 38, 39, 40, 41, and 42 have been omitted. This would avoid repetition of common activities between CIRP and liquidation process and ensure faster completion of the liquidation process. g. Realisation of Security Interest: Secured creditors must intimate the liquidator within fourteen days from liquidation commencement of their intention to realise security interest, failing which the asset is deemed relinquished. Secured creditors who realise their security interest are also required to contribute towards insolvency resolution process and liquidation costs and workmen’s dues from the proceeds of such realisation. 12. Secured Creditor is secured to the extent value of Security An Explanation has been inserted to clarify that where a secured creditor relinquishes security interest of a value lower than the total debt owed, such creditor will be treated as a secured creditor only to the extent of the value of the security interest determined in

5 the manner specified. For the remaining unpaid portion of the debt, the creditor will be treated as an unsecured creditor. 13. Distribution of government dues An Explanation has been inserted clarifying that all amounts due to the Central and State Governments, whether or not secured by contract or operation of law, relating to the two-year period preceding liquidation commencement, shall be distributed under sub-clause (i) of Section 53. Any remaining government dues, regardless of security status, shall be distributed under clause (f). This provides clarity to the priority of statutory dues in liquidation. 14. Restoration of CIRP The CoC may, with 66% voting share, apply for restoration of CIRP before a liquidation order is passed. The restored process must be completed within 120 days and is permitted only once. This provides an additional opportunity for resolution. 15. Penalty for frivolous proceedings: The AA is empowered to impose penalties ranging from one lakh to two crore rupees for initiating frivolous or vexatious proceedings. 16. Contravention of moratorium and resolution plan: Penalties are introduced for violation of moratorium and breach of resolution plan, applicable to CD, officers, and creditors. This strengthens compliance. 17. Strengthening Information Utility system The Amendment Act has made it mandatory for an OC to first submit financial information through IUs before filing an application under Section 9. Furthermore, the Amendment Act requires the CD or debtor to authenticate submitted financial information within a specified timeframe. In case no response is provided within the specified time, the information will be deemed to be authenticated. 18. Electronic Platform for Insolvency Processes New Section 240B empowers the Central Government to provide, by way of notification, an electronic portal and the procedures related to the insolvency and bankruptcy processes under the Code, which shall be carried out on such an electronic portal. 19. Interim Moratorium - Personal Guarantors It is clarified that interim moratorium provisions do not apply to insolvency proceedings against personal guarantors to corporate debtors. This enables continuation of creditor actions. 20. Strengthening regulatory powers of the Board The Amendment Act expressly empowers the Board to frame regulations and issue guidelines relating to insolvency and bankruptcy, as may be necessary for carrying out the purposes of the Code. The Board is also empowered to regulate service providers as per the revised definition of service providers, specify standards of conduct for the CoC, and levy fees in relation to all processes under the Code. Furthermore, the disciplinary framework has been strengthened, including imposition of higher penalties and an appellate mechanism against disciplinary orders. 21. Group Insolvency The Amendment Act empowers the Central Government to prescribe rules for insolvency proceedings initiated against two or more corporate debtors that form part of a group. The new framework enables coordinated insolvency proceedings for group entities, including common adjudicating authority (bench), common insolvency professional, group committee of creditors and coordination agreement between group companies. 22. Cross-border Insolvency The Central Government is now empowered to frame rules for administering cross-border insolvency proceedings. This includes provisions for recognition of foreign proceedings, granting of relief, judicial cooperation, and coordination with foreign jurisdictions for specified classes of debtors or countries as notified. It further allows the application of provisions of the Code or the Companies Act with necessary exceptions, modifications, and adaptations, including the designation of specific benches to handle such cases. Additionally, for the purpose of this section, the term “corporate debtor” is expanded to include persons incorporated with limited liability outside India 23. Creditor-Initiated Insolvency Resolution Process (CIIRP)  One of the most significant reforms introduced through the Amendment Act is the introduction of the CIIRP under a new Chapter IV-A of the Code. The new framework provides an additional resolution mechanism that is designed to enable faster and more efficient resolution of stress through a creditor-driven process with limited judicial intervention.  Under the existing CIRP insolvency proceedings commence only after admission of an application by the AA under sections 7, 9, or 10 of the Code. The CIIRP framework departs from this model by allowing notified FCs to initiate the process directly upon occurrence of default, subject to prescribed conditions and creditor approvals. The process formally commences upon public announcement by the RP rather than upon admission by the AA.  The framework is intended for specified categories of CDs, such as entities with assets or income below notified thresholds or debtors belonging to notified classes. CIIRP can be initiated only by notified FCs, and initiation requires approval of at least 51% in value of debt from eligible FCs. Before initiation, the CD must be informed of the proposed action and given 30 days to submit its representation.  Unlike the standard CIRP framework, management of the CD continues to remain with the Board of Directors during the CIIRP period, while the RP exercises supervisory oversight and attends meetings of the Board with veto powers. The framework therefore adopts a hybrid “debtor-in-possession, creditor-in-control” model. At the same time, provisions relating to avoidance transactions, fraudulent and wrongful trading, and ineligibility under section 29A continue to apply to ensure accountability and safeguard creditor interests.  CIIRP must ordinarily be completed within 150 days, extendable only once by a maximum of 45 days with approval of the CoC. If the process fails or if CoC so resolves, the AA may convert the process into a regular CIRP.  The framework also provides for withdrawal of the process with approval of 90% voting share of the CoC, subject to specified timelines. Resolution plans approved under CIIRP are submitted to the AA for approval under principles similar to section 31 of the Code, thereby ensuring statutory compliance and binding effect on stakeholders.  The introduction of CIIRP seeks to provide an additional and flexible insolvency resolution mechanism that allows early intervention by creditors, minimises value erosion, and reduces pressure on adjudicatory forums while maintaining necessary safeguards under the Code.

6 A. IBBI Updates A.1 Key Events 3rd International Conclave 2026 The IBBI in association with INSOL India organised the 3rd International Conclave 2026 on January 28, 2026 in New Delhi. Hon’ble Justice (Retd.) Ramalingam Sudhakar, President, National Company Law Tribunal graced the occasion as Chief Guest. Mr. M. Nagaraju, Secretary, Department of Financial Services, Ministry of Finance and Mr. Ravi Mital, Chairperson, IBBI delivered the special address on the occasion. Ms. Pooja Mahajan, President, INSOL India delivered the welcome address at the Conclave. Dr. Bhushan Kumar Sinha, Whole Time Member, IBBI delivered the vote of thanks at the conclusion of the inaugural session. The Conclave included five panel discussions on emerging themes in the insolvency and bankruptcy space – “10 Years of the Insolvency and Bankruptcy Code, 2016”; “Asset Tracing, Enforcement & Recovery”; “Out-of-Court Workouts & Pre-Pack Solutions”; “Financing Distressed Acquisitions & Special Situations”; and “UNCITRAL Model Law & Cross-Border Insolvency”. A large number of stakeholders of the IBC ecosystem, including insolvency professionals, legal practitioners, consulting firms, financial creditors, resolution applicants, service providers, regulators, academia, and government officers participated in the Conclave. 3rd International Conclave 2026, New Delhi, January 28, 2026 3rd International Conclave 2026, New Delhi, January 28, 2026 3rd International Conclave 2026, New Delhi, January 28, 2026 3rd International Conclave 2026, New Delhi, January 28, 2026 3rd International Conclave 2026, New Delhi, January 28, 2026 International Women’s Day 2026 The IBBI celebrated International Women’s Day 2026 on March 06, 2026. Ms. Ravneet Kaur, Chairperson of the Competition Commission of India, graced the event as the Chief Guest, and delivered a keynote address that inspired attendees. Ms. Kaur eloquently recounted her personal and professional journey, offering a practical roadmap gleaned from her experiences. She highlighted the critical importance of exercising independent judgment and stressed the integrity required to honour one’s own decisions. Emphasizing that autonomy and self-accountability are vital for long-term success, Ms. Kaur called on women to carve out a place for themselves in professional forums to ensure their voices are heard. The program witnessed enthusiastic participation from lady officers, consultants and research

7 associates of IBBI, who engaged in insightful discussions, fostering a spirit of empowerment and collaboration among attendees. Women’s day celebrations, New Delhi, March 8, 2026 A.2 Reports Report of Committee on Framing Guidelines for Insolvency Proceedings in Real Estate Sector The IBBI had constituted the Committee on Framing Guidelines for Insolvency Proceedings in the Real Estate Sector pursuant to the directions of the Hon’ble Supreme Court in Mansi Brar Fernandes v. Shubha Sharma & Ors. (judgment dated 12 September 2025). The Supreme Court, recognising the distinct challenges posed by real estate insolvency, had directed the formulation of sector-specific guidelines, including timelines for project-wise Corporate Insolvency Resolution Processes (CIRP) and safeguards for homebuyers. The Committee was chaired by Shri Jayanti Prasad, Whole Time Member, IBBI, and comprised representatives from the Ministry of Corporate Affairs, Ministry of Housing and Urban Affairs, RERA Uttar Pradesh, RERA Haryana (Gurugram), All India Forum of RERAs and Haryana Shahri Vikas Pradhikaran. In discharging its mandate, the Committee adopted a consultative and evidence-based approach. It held multiple meetings and engaged extensively with stakeholders including financial institutions, insolvency professionals, successful resolution applicants, industry associations, homebuyer representatives, and former adjudicating authority members. The Committee also analysed judicial precedents, empirical data, and practical challenges emerging from ongoing and concluded real estate insolvency proceedings. Understanding the distinct nature of real estate insolvency The Committee’s analysis underscores that real estate insolvency differs fundamentally from insolvency in other sectors. Unlike conventional corporate insolvency, where the primary objective is value maximisation for creditors, real estate insolvency involves large numbers of dispersed homebuyers whose principal expectation is not financial recovery but completion of projects and delivery of homes. The Committee identified several structural challenges that have affected outcomes under the existing framework. These include fragmented SPV-based project structures, multiple projects under a single corporate debtor, diversion or freezing of project funds, inconsistencies in the conduct of development authorities, lapsing approvals during CIRP, and the complexity of managing large volumes of homebuyer claims. It also noted concerns relating to weak post-approval monitoring, delays in adjudication, and limited participation by credible resolution applicants due to informational and regulatory uncertainties. These issues, taken together, have often resulted in prolonged insolvency processes without meaningful progress on construction, thereby undermining the core objective of delivering homes and reviving viable projects. Core Reform Approach: From Entity-Centric to Project-Centric Insolvency At the heart of the Committee’s recommendations is a paradigm shift from an entity-centric insolvency framework to a project-centric, completion-oriented approach. The Committee examined 55 issues and made 155 recommendations aimed at improving efficiency, enhancing stakeholder confidence, and ensuring timely delivery of housing units. Key Recommendations of the Committee  Project-wise admission and conduct of CIRP: The Committee recommends that insolvency proceedings in the real estate sector should ordinarily be admitted and conducted on a project-wise basis. Each project should be treated as an independent economic unit, with CIRP confined to the defaulting project. Solvent or unrelated projects should not be drawn into insolvency, except in exceptional cases involving significant interlinkages or fraud, with reasons recorded by the Adjudicating Authority.  Increase in threshold for initiation of CIRP: Recognising the scale and capital intensity of real estate projects, the Committee recommends increasing the minimum default threshold for initiation of CIRP from Rs. 1 crore to Rs. 5 crore for real estate cases. This is intended to prevent premature or fragmented insolvency triggers, while existing safeguards—such as the requirement of at least 100 allottees or 10% of total allottees— continue to ensure access for genuine homebuyers.  Completion-first approach: Prioritising possession over recovery: The Committee emphasises that the primary objective of real estate insolvency should be completion of projects and delivery of possession. Resolution plans should be structured around construction completion, with refund- based outcomes where completion is not viable.  Facilitating possession during CIRP: The Committee supports enabling handover of possession to homebuyers during the CIRP itself in cases where units are complete or substantially complete and payment obligations have been met. This reduces hardship and aligns the process with the fundamental objective of housing delivery.  Treatment of refund and possession preferences: While recognising that homebuyers may have differing preferences—some seeking refunds and others seeking possession—the Committee recommends that allottees continue to be treated as a single class of financial creditors

8 for voting purposes. However, resolution plans should, to the extent feasible, accommodate both categories through appropriate structuring.  Distinguishing speculative investors and genuine homebuyers: The Committee acknowledges the need to prevent misuse of the insolvency framework by speculative investors. It recommends that the Adjudicating Authority examine the nature of transactions at the admission stage, applying judicially evolved criteria, while maintaining a uniform treatment of financial creditors within the insolvency process.  Provision for All Recorded Allottees: The Resolution plans should duly provide for all allottees reflected in corporate or RERA records, regardless of whether they are filed through a formal claim process or not. This ensures that genuine homebuyers are not excluded from relief due to procedural lapses or a lack of awareness.  Strengthening the role of RERA and regulatory convergence: Enable RERA authorities to nominate representatives as observers in the CoC meetings and provide an opportunity to submit opinions in writing on the regulatory feasibility of resolution plans. The RERA should be represented in project monitoring committees post-plan approval to facilitate expedited approvals and statutory compliance during the implementation phase. Additionally, clear guidelines should be issued to ensure post-resolution regulatory certainty, mandating that all statutory obligations be enforced prospectively and that past non-compliances be addressed solely in accordance with the approved plan.  Operationalisation of project-wise escrow accounts: The Committee recommends mandatory operation of project- specific escrow accounts during CIRP, ensuring that funds are used exclusively for the concerned project. It also emphasises that such accounts should not be frozen upon insolvency admission, and that cross-utilisation of funds should be strictly controlled.  Framework for engagement with development authorities: Given the critical role of land-owning and development authorities, the Committee recommends the formulation of standard operating procedures governing their role during CIRP. These include restructuring of dues, adherence to moratorium provisions, and recognition of the binding nature of approved resolution plans.  Strengthening post-approval monitoring: To bridge the gap between plan approval and actual project completion, the Committee recommends constitution of Project Monitoring Committees comprising of key stakeholders. It also envisages a stronger role for RERA in post-resolution oversight to ensure adherence to timelines and commitments.  Improving market participation and resolution quality: The Committee recommends enhancing the quality of Information Memorandum, encouraging participation of homebuyer associations as resolution applicants, and promoting involvement of public sector entities as project managers or resolution applicants. It also highlights the importance of clarity on “clean slate” protections to attract credible investors. Towards a more integrated and responsive framework A key theme running through the Report is the need for regulatory convergence. The Committee recognises that real estate insolvency lies at the intersection of insolvency law, urban development, financial regulation, and consumer protection. It therefore emphasises coordinated functioning of institutions such as IBBI, RERA authorities, development authorities, and financial regulators. The recommendations also reflect a broader shift in policy thinking

• from a recovery-driven approach to a completion-driven framework. The Committee underscores that the success of insolvency in the real estate sector must ultimately be measured not by resolution timelines alone, but by the number of homes delivered and projects revived. The full report is available on the website of IBBI at https:// ibbi.gov.in/uploads/resources/e3843d2d5ab054f330e159b 28b7dc3a4.pdf . Submission of Real Estate Committee Report, New Delhi, April 20, 2026 Report of the Committee on Drafting of Regulations - IBC (Amendment) Bill, 2025 The IBBI had constituted a Committee under the chairmanship of Shri Jayanti Prasad, Whole Time Member, IBBI to examine the implications of the Insolvency and Bankruptcy Code (Amendment) Bill, 2025 on the existing regulations framed under the Code and to propose necessary amendments to the regulations. The Committee adopted a principles-based approach, guided by the following considerations: (a) fidelity to the legislative intent as expressed in the Amendment Bill and the recommendations of the Parliamentary Select Committee; (b) operational efficiency and clarity in regulatory processes; (c) minimisation of regulatory burden on stakeholders while ensuring adequate safeguards; (d) consistency and harmonisation across the regulatory framework; and (e) facilitation of the objectives of the Code, namely, time-bound resolution, value maximisation, and balancing the interests of all stakeholders. The Committee has held several meetings and has deliberated upon the amendments impacting the corporate insolvency resolution process, liquidation process, voluntary liquidation process, individual insolvency framework for personal guarantors to corporate debtors, information utilities, and other regulations framed under the Code.

9 The Amendment Bill introduces both clarificatory amendments and substantive amendments. The Committee examined provisions of the Amendment Bill, studied the Parliamentary Select Committee’s final recommendations, reviewed the existing regulations, and proposed amendments thereto. The full report is available on the website of IBBI at https:// ibbi.gov.in/uploads/resources/2b9fe26449e9960a2dadf081cb 3d2dd3.pdf Report of Study on Effectiveness of the Resolution Process: Firm Outcomes in the post-IBC Period The Indian Institute of Management Ahmedabad conducted a study titled “Effectiveness of the Resolution Process: Firm Outcomes in the Post-IBC Period”, examining the post-resolution performance of firms under the IBC. As the Code completes a decade, the study provides empirical insights into whether resolved firms have been able to revive and create value after resolution. The study builds on an earlier 2023 analysis and extends the dataset up to 2025, covering a total of 1194 firms that underwent resolution, thereby capturing more recent trends and outcomes. The key findings of the report are as given below:  Sales: Increased by ~89% over five years post-resolution, indicating business revival.  Asset Turnover: Improved by ~131%, reflecting better asset utilisation.  CAPEX: Increased by ~106%, showing renewed investment activity.  Average Assets: Grew by ~11.5% over five years, indicating expansion in asset base.  Employee Metrics: Employee expenses increased by ~72%, with employee intensity rising ~200%, suggesting higher workforce engagement.  Market Capitalisation: Significant recovery, with aggregate valuation rising from ~ Rs. 2.8 lakh crore to ~ Rs. 9 lakh crore.  Liquidity: Improved by ~106%, indicating stronger financial position and solvency. Overall, the findings underscore the effectiveness of the IBC framework in improving financial and operational health, driving investment, enhancing efficiency, and supporting long-term value creation in resolved firms. The full report is available on the website of the Insolvency and Bankruptcy Board of India at https://ibbi.gov.in/uploads/resources/ f42521011e8c39d591a8f1b439a80da7.pdf. Research study on ‘Micro, Small and Medium Enterprises in the Insolvency and Bankruptcy Code’ conducted by Management Development Institute, Gurgaon The Management Development Institute, Gurgaon has undertaken a research study titled “Micro, Small and Medium Enterprises in the Insolvency and Bankruptcy Code.” The study presents an assessment of the Micro, Small and Medium Enterprises (MSMEs) under the Insolvency and Bankruptcy Code, 2016 since its inception and offers an examination of the role of MSMEs in insolvency proceedings under the Code, both in their capacity as OCs and as CDs. The study highlights several recommendations to strengthen the insolvency framework for MSMEs. It calls for the systematic collection and publication of data on pre-admission recoveries and settlements. It suggests mandating structured recording of operational creditor invoices (Rs. 1 crore and above) by NeSL. To improve access, the study proposes allowing aggregation of claims by MSME operational creditors and reducing related procedural costs. It also recommends a recovery-focused auction model guided by a quasi-Absolute Priority Rule, alongside replacing the “no impairment” clause in PPIRP with a principle- based allocation. Further, it advocates separating avoidance transaction reviews from the core resolution process, while keeping resolutions provisional, and emphasises enhancing awareness and capacity building for MSMEs through targeted outreach and support initiatives. The findings of this study offer insights into the evolving role and experience of MSMEs under the insolvency framework and contribute to an understanding of the practical challenges, emerging trends, and potential areas for MSMEs. The full report is available on the website of the Insolvency and Bankruptcy Board of India at https://ibbi.gov.in/uploads/resources/ 7373b47de45dd16da8313f1863709fcb.pdf. Research study on Resolution Professionals conducted by Management Development Institute, Gurgaon The Management Development Institute, Gurgaon has undertaken a research study titled “Study on Resolution Professionals”. The study examines the role, responsibilities, and functioning of RPs within the CIRP under the IBC. The study recommends strengthening the insolvency ecosystem and enhancing the role of IPs. It proposes expanding eligibility to include professionals with managerial and financial expertise. For large CIRPs above Rs. 1,000 crore, it suggests a dual structure where IPs or IPEs handle resolution and compliance, while a specialised SPV manages operations. The study also recommends introducing a case-based examination system for IPs, similar to those in the US and UK. To safeguard the integrity of the process, it suggests that IPs found guilty of fraudulent conduct should be removed from all assignments, including ongoing cases. Further, the report recommends that Resolution Professionals provide a performance guarantee after their appointment, ensure the arm’s length appointment of valuers through an open and fair process, and undertake structured capacity-building and training programmes for IPs and IPEs. The report provides valuable insights into the role and responsibilities of Resolution Professionals in India’s insolvency framework and offers recommendations to further strengthen the effectiveness, transparency, and efficiency of the CIRP under the IBC. The full report is available on the website of the Insolvency and Bankruptcy Board of India at https://ibbi.gov.in/uploads/resources/ bcfead24a4ac23bbf2a1bbaf4cd660dc.pdf.

10 A.3 Human Resources Appointment of Mr. Ashutosh Mishra as ex-officio member in IBBI Mr. Ashutosh Mishra was appointed as an ex-officio member in the Governing Board of IBBI, representing the Ministry of Law and Justice, vide notification dated February 26, 2026. He is presently serving as Additional Secretary in the Department of Legal Affairs under the Ministry of Law and Justice. Belonging to the Indian Legal Service, he has over 29 years of experience in the Central Government and has held key positions, including Joint Secretary and Legal Adviser in the Department of Legal Affairs. He has been involved in providing legal advice to various Ministries and Departments of the Government of India. He holds a Master’s degree in Management Studies from Utkal University, Bhubaneswar, and an LL.M. degree from RTM Nagpur University, Nagpur. He is also a Member of the Governing Body and Council of the Indian Council of Arbitration as a nominee of the Government of India. Appointment of Ms. Aparna Sinha as ex-officio member in IBBI Ms. Aparna Sinha was appointed as an ex-officio member in the Governing Board of IBBI, representing the Ministry of Finance vide notification dated March 24, 2026. She is currently serving as Economic Adviser in the Department of Economic Affairs under the Ministry of Finance. A 1999-batch officer of the Indian Economic Service, she has extensive experience in economic policy, international trade, and financial sector matters, having served in the Regional Evaluation Organization of the erstwhile Planning Commission (now NITI Aayog), the Department of Commerce handling services trade negotiations, and as Counsellor (Services) at the Permanent Mission of India to the World Trade Organization, Geneva. She holds a Bachelor’s degree (Economics Honours) from Hindu College, University of Delhi, and a Master’s degree in Economics from Annamalai University, and is presently dealing with a wide range of financial sector issues, including the digital economy and fintech, financial stability, cybersecurity, legislative and regulatory reforms, financial inclusion, and crypto-sector matters. A.4 Employee Trainings and Workshops The members and officers of IBBI attended the following workshops and training programmes. Date Organised Nature of the programme/ No. of by Subject officers 09.02.2026 IBBI Programme on Karmayoga – 40 A Framework for Stress-Free Working 14.02.2026 Ministry of National Conference on 2 Women and Child Safety of Women Workplace Development 02.03.2026 IBBI “Seva Sankalp Resolution” 40 adopted by the Union Cabinet Martyrs’ Day, New Delhi, January 30, 2026 Programme on Karmayoga – A Framework for Stress-Free Working, New Delhi, February 9, 2026 B. Legal and Regulatory Framework B.1 Central Government Passing of The Insolvency and Bankruptcy Code (Amendment) Act, 2026 The Insolvency and Bankruptcy Code (Amendment) Bill, 2025, as reported by Select Committee, was passed by the Lok Sabha and Rajya Sabha on March 30, 2026 and April 1, 2026 respectively. The Insolvency and Bankruptcy Code (Amendment) Act, 2026 received the President’s assent on 06 April, 2026. B.2 Regulations IBBI (Liquidation Process) (Amendment) Regulations, 2026 The IBBI notified the IBBI (Liquidation Process) (Amendment) Regulations, 2026 on January 2, 2026. The Amendment requires the liquidator to file Liquidation Process Forms, along with Mr. Ashutosh Mishra, Additional Secretary, Ministry of Law & Justice Ms. Aparna Sinha, Economic Adviser, Ministry of Finance

11 enclosures, as notified by the Board from time to time, on an electronic platform of the Board within the stipulated timelines for each Form. The revised forms have been designed to reduce compliance burden by eliminating duplications, rationalising data requirements and leveraging technology for auto-population of information already available on the portal. Consequently, these revisions are expected to significantly reduce compliance burden, while continuing to ensure that the Board receives all essential information in a timely manner. IBBI (Insolvency Resolution Process for Corporate Persons) (Amendment) Regulations, 2026 The IBBI notified the IBBI (Insolvency Resolution Process for Corporate Persons) (Amendment) Regulations, 2026, on February 25, 2026. The amendments broadly relate to the following:- Enhanced disclosures in IM  The IM must include details of all receivables of the corporate debtor, including trade receivables, inter-corporate receivables, and receivables arising under any contract;  Details of joint development agreements and other similar collaboration or co-development arrangements, including rights, obligations, and interests of the corporate debtor arising thereunder;  Details of assets which are under attachment by enforcement agencies, including particulars of the assets attached, the authority which has attached and the status of such proceedings. Measures for homebuyers/ allottees  Disclosure of all allottee details in IM: Details of all allottees, including their names, amounts due, and units allotted, whose claims are either reflecting in the books of accounts of the CD or in the records of RERA, but have not submitted their claims to the resolution professional, shall be disclosed in the IM.  Treatment of allottees not filing claims: In respect of a real estate project, where the IM includes the details of the allottees who have not submitted their claims, the resolution plan shall provide for treatment of such allottees. Amendments related to Valuation The IBBI undertook major and transformative regulatory reforms to significantly strengthen the valuation framework under the IBC. In this regard, the following amendment Regulations were notified on February 25, 2026:  IBBI (Insolvency Resolution Process for Corporate Persons) (Amendment) Regulations, 2026  IBBI (Bankruptcy Process for Personal Guarantors to Corporate Debtors) (Amendment) Regulations, 2026  IBBI (Liquidation Process) (Second Amendment) Regulations, 2026  IBBI (Pre-Packaged Insolvency Resolution Process) (Amendment) Regulations, 2026  IBBI (Voluntary Liquidation Process) (Amendment) Regulations, 2026 The CIRP Amendment Regulations provide for the following reforms in the valuation framework:  Refined definition of “Fair Value”: The definition of ‘fair value’ has been amended to clarify that the valuation of the CD shall take into account the estimated realizable value of all its assets, including tangible and intangible assets along with their underlying synergies, thereby strengthening the enterprise- level valuation framework under the resolution process.  Appointment of Registered Valuers: Regulation 27 of the CIRP Regulations provides that the resolution professional shall appoint two sets of RVs to determine the fair value and liquidation value of the CD. Each set consists of one RV for each asset class of the CD.  Role of Coordinating Valuer: Within each set of valuers, one valuer is designated as the coordinating valuer, who computes the fair value of the CD after considering the valuation estimates of all asset classes and their underlying synergies. This structure ensures consolidation and consistency in valuation estimates.  Transparency in Valuation Methodology: The regulations require that the RVs explain the methodology proposed to be adopted for valuation to the CoC before computation of estimates, thereby enabling the CoC to understand the valuation approach and assumptions being adopted.  Physical Verification and Valuation Standards: Each RV is required to undertake physical verification of the inventory and fixed assets of the CD and submit valuation reports prepared in accordance with valuation standards notified by the Board through circulars.  Provision for Appointment of Third Set of Valuers: The regulations further provide that the resolution professional may appoint a third set of RVs where the estimates of fair value or liquidation value are significantly different, or where the Committee of Creditors proposes such appointment for recorded reasons. A difference of 25% or more in valuation estimates is treated as significant for this purpose.  Determination of Final Valuation: The regulations prescribe a structured method for determination of the final valuation. The average of the two closest estimates is considered as the fair value and liquidation value respectively, thereby mitigating the impact of outlier valuations.  Standardisation of Valuation Reports: The regulations also require that valuation reports and related documentation be prepared and maintained in formats notified by the Board, which strengthens regulatory oversight and ensures consistency and auditability of valuation processes. Similar changes to valuation provisions were introduced simultaneously across all relevant regulations to ensure consistency and regulatory alignment . B.3 Circulars Launch of Revised Forms for Liquidation Process Revised liquidation process Forms (LIQ-1 to LIQ-4) have been introduced vide circular dated January 5, 2026 which are required to be filed on the electronic platform of the Board as per the timelines stipulated for each form. In order to facilitate IPs to familiarise themselves with the revised forms and resolve any technical issue(s) that may arise, no penalty will be levied on

12 delayed filing of forms, during the initial quarter (January – March 2026). Filing Forms to monitor insolvency resolution processes for PG to CD Vide circular dated March 6, 2026 a set of electronic forms (PGIRP1 to PGIRP6) have been introduced to capture details of the insolvency resolution process for PG to CD. The framework provides for filing through an electronic platform with DSC/e-sign, availability of a modification utility, deferment of penalty for delayed submission till June 30, 2026, and specific timelines for filing forms in ongoing and concluded cases. B.4 Invitation of public comments Discussion Paper on strengthening CoC’s oversight and procedural clarity under the CIRP Regulations The IBBI issued a discussion paper on February 16, 2026 with a view to addressing implementation challenges, removing procedural ambiguities, and enhancing the efficiency, predictability, and integrity of the corporate insolvency resolution process under the Code. Based on feedback received from stakeholders and issues observed during the conduct of CIRPs, the Board has identified certain areas where greater procedural clarity is required to avoid inconsistencies, disputes, escalation of costs, or sub- optimal value outcomes. Accordingly, the discussion paper proposes amendments to the CIRP Regulations in relation to the following areas: (i) Strengthening recording of CoC deliberations while approving resolution plans by providing greater clarity on the scope of matters to be recorded, including expected recovery for creditors in comparison with the fair value and liquidation value, adequacy of market discovery, and capability and credibility of the resolution applicant and certainty of implementation of the resolution plan. (ii) Rationalisation of the framework for approval of insolvency resolution process costs and decision-making on continuation of operations of the corporate debtor as a going concern by introducing a calibrated regulatory framework with defined limitations on costs during the initial phase, mandatory placement of a Going Concern Assessment Report before the CoC, and requirement of prior approval of the CoC for all subsequent costs to ensure transparency and cost discipline. (iii) Clarification of the role of the Committee of Creditors in respect of delayed claims by expressly providing that all delayed claims categorised as acceptable by the resolution professional shall be placed before the Adjudicating Authority for condonation of delay and adjudication, and before the CoC only for its recommendation regarding their treatment in the resolution plan. (iv) Exclusion of related operational creditors from participation in committees of creditors constituted exclusively of operational creditors to preserve independence, neutrality, and creditor primacy, and to prevent conflicts of interest and circumvention of CoC neutrality. The last date for submission of comments electronically was March 10, 2026. C. Corporate Processes The data provided in this section regarding corporate processes is provisional, as it is getting revised on a continuous basis depending on the flow of updated information as received from IPs or the information in respect of process changes. For example, a process may ultimately yield an order for liquidation even after approval of resolution plan or may ultimately yield resolution plan even after an order for liquidation. C.1 Overview The provisions relating to CIRP came into force on December 1, 2016. The details of CIRP cases admitted and closed, as at the end of March 2026 are given in Table 1 and Figures 1-2. Sectoral distribution of CDs under CIRP is presented in Figures 3-6. The Code has rescued 4099 CDs (1419 through resolution plans, 1388 through appeal or review or settlement and 1292 through withdrawal) till March 2026. It has referred 3003 CDs for liquidation. The resolved CDs resulted in realisation of more than 30.56% as against the admitted claims and more than 166.85% as against the liquidation value. Resolution plans on average are yielding 94.56% of fair value of the CDs. Till March 2026, 1692 CDs have been completely liquidated. These 1692 CDs together had outstanding claims of Rs. 4.85 lakh crore, but the assets valued at Rs. 0.21 lakh crore. The liquidation of these companies resulted in 86.34% realisation as against the liquidation value. Table 1: Details of CIRP cases as on March 31, 2026 Status of CIRPs No. of CIRPs Admitted 8987 Closure: 7102 Withdrawn under section 12A 1292 Closed on appeal or review or settled 1388 Resolution plans approved 1419 Liquidation orders passed 3003 Ongoing CIRP cases 1885 Note: This excludes 1 CD which has moved directly from Board for Industrial and Financial Reconstruction (BIFR) to resolution. Source: Compilation from website of the NCLT and filing by IPs. Figure 1: Corporate Insolvency Resolution Process

13 Commencement of Liquidation (42%) Resolved/ Appeal/ Review/ Settled/ Withdrawn (58%) Figure 2: Mode of Closure of CIRPs Figure 3: Sectoral Distribution of CIRPs: Admission Figure 4: Sectoral Distribution of CIRPs: Appeal/Review/Settled/Withdrawn Figure 5: Sectoral distribution of CIRPs: Resolution plans Figure 6: Sectoral distribution of CIRPs: Commencement of liquidation The outcome of CIRPs, initiated stakeholder-wise, as on March 31, 2026 is presented in Table 2. Of the OC initiated CIRPs that were closed, around 51% were closed on appeal, review, or withdrawal. Such closures accounted for more than 66% of all closures by appeal, review, or withdrawal. Table 2: Outcome of CIRPs, initiated Stakeholder-wise, as on March 31, 2026 Outcome Description CIRPs initiated by FCs OCs CDs FiSPs Total Status of Closure by Appeal/Review/Settled 454 920 14 0 1388 CIRPs Closure by Withdrawal u/s 12A 410 871 11 0 1292 Closure by Approval of 884 438 93 4 1419 Resolution Plan Closure by Commencement of 1424 1251 328 0 3003 Liquidation Ongoing 1143 629 112 1 1885 Total 4315 4109 558 5 8987 CIRPs Realisation by creditors as % 177.96 149.42 146.83 134.94 166.85 yielding of Liquidation Value Resolution Realisation by creditors as % 30.61 24.82 17.99 41.41 30.56 Plans of their Claims Average time taken for Closure 751 756 629 677 744 of CIRP CIRPs Liquidation Value as % of Claims 5.37 8.32 7.46

6.02 yielding Average Time taken for order of 540 541 453

531 Liquidations Liquidation C.2 Stakeholder-wise initiation of CIRP The distribution of stakeholder-wise initiation of CIRPs is presented in Table 3. FCs triggered 48.04% of the CIRPs, followed by about 45.75% by OCs and remaining by the CDs. It is observed that about 80% of CIRPs having an underlying default of less than Rs. 1 crore were initiated on applications by OCs while about 80% of CIRPs having an underlying default of more than Rs. 10 crores were initiated on applications by FCs. The share of CIRPs initiated by CDs is declining over time.

14 Table 4: Average Time for Approval of Resolution Plans/Orders for Liquidation Time (In days) Sl. Average time As on March, 2024 As on March, 2025 April, 25 - March, 2026 No. of Time No. of Time No. of Time Processes Including Excluding Processes Including Excluding Processes Including Excluding covered excluded excluded covered excluded excluded covered excluded excluded time time time time time time CIRPs 1 From ICD to approval of resolution 927 675 563 1186 717 597 233 886 751 plans by AA 2 From ICD to order for Liquidation by AA 2467 492 NA 2757 507 NA 246 801 NA Liquidations 3 From LCD to submission of final 1090 606 NA 1436 650 NA 256 926 NA report under Liquidation 4 From LCD to submission of final 1412 409 NA 1743 401 NA 279 351 NA report under Voluntary Liquidation 5 From LCD to order for dissolution 700 734 NA 953 784 NA 168 1032 NA under Liquidation 6 From LCD to order for dissolution 962 721 NA 1229 737 NA 313 737 NA under Voluntary Liquidation Table 3: Year-wise and Stakeholder-wise Initiation of CIRPs Year / Quarter No. of CIRPs initiated by Total FCs OCs CDs 2016 - 17 8 7 22 37 2017 - 18 286 310 111 707 2018 - 19 517 569 71 1157 2019 - 20 883 1057 51 1991 2020 - 21 197 318 22 537 2021 - 22 372 474 43 889 2022 - 23 654 538 70 1262 2023 – 24 536 402 66 1004 2024 - 25 451 227 55 733 April - Jun, 2025 102 73 13 188 July-Sept, 2025 97 54 13 164 Oct-Dec, 2025 115 45 10 170 Jan-Mar, 2026 97 35 11 143 Total 4315 4109 558 8982 Note: This excludes five cases wherein applications filed by the RBI were admitted u/s 227 of the Code. C.3 Timelines C.3.1 For Concluded Processes The Code endeavours to close the various processes at the earliest. The 1419 CIRPs, which have yielded resolution plans by the end of March, 2026 took on average 621 days (after excluding the time excluded by the AA) for conclusion of process, while incurring an average cost of 1.30% of liquidation value and 0.80% of resolution value. Similarly, the 3003 CIRPs, which ended up in orders for liquidation, took on average 531 days for conclusion. Further, 1692 liquidation processes, which have closed by submission of final reports took on average 691 days for closure. Similarly, 2022 voluntary liquidation processes, which have closed by submission of final reports, took on average 394 days for closure. The average time taken for completion of various processes is presented in Table 4. C.3.2 For Ongoing CIRPs The status of ongoing CIRPs in terms of time taken, as of March, 2026, is presented in Figure 7. Figure 7: Timeline: Ongoing CIRPs C.4 Resolution Plans C.4.1 Overall outcomes Till FY 2024-25, 1194 CIRPs had yielded resolution plans. The creditors realised Rs. 3.89 lakh crore under the resolution plans, in these cases. The liquidation value of the assets available with these CDs, when they entered the CIRP, was at Rs. 2.29 lakh crore against the total claims of the creditors worth Rs. 11.87 lakh crore. The realisation to the creditors was 32.76% and 170.09% as against their admitted claims and liquidation value, respectively. Till December 2025, 1376 CIRPs had yielded resolution plans. The creditors realised Rs. 4.11 lakh crore under the resolution plans, in these cases. The fair value and liquidation value of the assets available with these CDs, when they entered the CIRP, was estimated at Rs. 3.66 lakh crore and Rs. 2.40 lakh crore,

15 Table 5: CIRPs Yielding Resolution Plans Sl. Name of Corporate Debtor Defunct Date of Date of CIRP Amount (in Rs.crore) Realisable Value as % of (Yes / Commen- Approval initiated Total Liquid- Fair Total Admit- Liquid - Fair No) cement of Resolu- by Admitted ation Value Realisable ted ation Value* of CIRP tion Plan Claims Value Amount by Claims Value Claimants Part A: Reported for Prior Period (Till December, 2025) 1 Incab Industries Ltd. Yes 07-08-2019 03-12-2025 OC 3346.52 429.24 511.74 566.50 16.93 131.98 110.70% 2 Kejriwal Sugar Agencies Private Limited Yes 22-04-2024 16-12-2025 OC 26.85 0.90 1.84 1.61 6.01 178.74 87.70% 3 Nectar Prints Private Limited Yes 09-05-2024 27-11-2025 OC 28.33 0.42 0.63 0.35 1.24 83.21 56.00% 4 Alishan Veneer & Plywood Private Limited Yes 05-06-2024 16-12-2025 OC 84.66 19.36 24.95 21.57 25.48 111.39 86.47% 5 Nexus Feeds Limited Yes 04-08-2021 28-11-2025 OC 213.86 36.19 86.31 80.75 37.76 223.13 93.56% 6 ABC Railroad Products Private Limited Yes 01-02-2024 06-08-2025 FC 59.27 0.47 0.52 0.36 0.61 77.42 69.23% 7 Jomer Properties and Investments Pvt Ltd Yes 16-02-2024 23-07-2025 FC 249.24 4.99 6.45 5.49 2.20 110.22 85.18% 8 Durha Vitrak Private Limited Yes 08-11-2019 13-10-2025 FC 54.19 33.99 49.88 48.44 89.40 142.50 97.11% 9 Ambition Mica Limited

06-03-2024 30-10-2025 OC

Part B: For January-March, 2026 1 Raigarh Champa Rail Infrastructure Private Ltd. No 01-01-2021 21-01-2026 FC 543.73 206.22 293.74 700.10 128.76 339.49 238.34% 2 Tmw Fintech Private Limited No 08-10-2021 12-01-2026 OC 43.72 0.36 0.36 0.48 1.10 132.02 131.91% 3 Valueworth Capital Management Private Limited Yes 22-11-2022 08-01-2026 CD 0.03 0.00 0.01 0.01 22.03 160.70 50.54% 4 Laxmi Pipes Limited No 17-05-2023 22-01-2026 OC 62.27 23.40 31.39 30.27 48.60 129.36 96.42% 5 Shiva Shakti Grains (India) Private Limited Yes 08-06-2023 16-01-2026 FC 7.23 0.16 0.16 0.86 11.87 554.02 554.02% 6 Call Express Construction (India) Private Ltd. No 05-07-2023 12-01-2026 OC 101.49 93.20 116.80 47.17 46.48 50.61 40.38% 7 E Commerce Magnum Solution Ltd No 01-07-2024 22-01-2026 FC 509.25 115.54 135.93 345.60 67.86 299.12 254.25% 8 Newgen Ecotronics Private Limited No 21-08-2024 22-01-2026 FC 28.66 7.53 9.29 8.06 28.11 106.93 86.75% 9 Sambandh Finserve Private Limited No 05-09-2024 20-01-2026 FC 641.00 30.41 30.63 30.22 4.71 99.37 98.65% 10 Sevenhills Healthcare Private Limited No 13-03-2018 19-01-2026 FC 1194.03 529.22 803.74 456.00 38.19 86.16 56.73% 11 Megi Agro Chem Limited No 05-08-2022 29-01-2026 FC 162.94 7.88 9.03 17.51 10.75 222.19 194.00% 12 Ncr Rail Infrastructure Limited No 07-03-2024 22-01-2026 FC 2736.66 150.66 206.68 461.74 16.87 306.48 223.41% 13 C and M Farming Limited Yes 21-03-2024 09-01-2026 FC 174.33 63.47 87.61 95.70 54.90 150.78 109.24% 14 Rsi Private Limited No 24-04-2024 22-01-2026 CD 93.04 0.90 1.40 1.01 1.08 112.13 72.05% 15 Lgcl Urban Homes (India) Llp No 14-11-2024 19-01-2026 FC 23.43 9.00 11.13 29.37 125.34 326.31 263.98% 16 Hotel Horizon Private Limited Yes 19-11-2024 29-01-2026 FC 1293.64 431.60 539.55 886.91 68.56 205.49 164.38% 17 Tranzlease Holdings (India) Private Limited Yes 04-12-2024 30-01-2026 OC 23.38 1.91 2.27 6.71 28.71 352.08 295.50% 18 Rajeswari Infrastructure Limited No 10-05-2023 13-01-2026 FC 35.34 12.42 17.60 11.99 33.94 96.57 68.15% 19 Reliance Innoventures Private Limited No 15-06-2023 06-01-2026 FC 4215.35 73.20 97.55 173.23 4.11 236.65 177.58% 20 Arcuttipore Tea Co Ltd No 15-12-2023 04-02-2026 FC 23.96 12.30 15.40 5.41 22.57 43.97 35.12% 21 Doshi Holdings Private Limited No 19-02-2021 23-02-2026 FC 4.48 0.15 0.25 3.01 67.17 2025.57 1193.97% 22 Rajesh Construction Company Private Limited Yes 13-05-2021 29-01-2026 FC 2656.09 45.30 77.14 60.97 2.30 134.60 79.04% 23 Krystal Stone Exports Limited Yes 03-05-2024 23-02-2026 FC 31.99 15.97 21.35 17.37 54.31 108.76 81.38% 24 Rudra Auto Tech Engineering Private Limited Yes 03-06-2024 20-01-2026 FC 115.31 6.68 8.74 7.62 6.61 114.10 87.16% 25 Gf Toll Road Private Limited No 23-10-2024 23-02-2026 FC 501.14 65.63 76.82 81.83 16.33 124.68 106.52% 26 Vetshield International Private Limited Yes 05-02-2025 03-02-2026 OC 72.60 0.16 0.33 0.10 0.14 60.88 30.44% 27 Renaissance Indus Infra Private Limited No 31-03-2023 17-02-2026 FC 1385.02 49.85 68.17 55.00 3.97 110.34 80.68% 28 Mona Portfolio Limited Yes 05-12-2024 17-02-2026 FC 77.39 0.00 0.00 2.65 3.42

29 Evyavan Mercantile Private Limited Yes 02-11-2023 23-02-2026 FC 48.26 0.07 0.39 0.45 0.93 642.86 115.38% 30 Pushp Ratna Realty Private Limited No 16-10-2024 09-03-2026 FC 23.96 21.18 24.92 17.53 73.17 82.79 70.36% respectively, as against the total claims of the creditors worth Rs. 12.99 lakh crore. The realisation to the creditors was 31.63% and 171.54% as against their admitted claims and liquidation value, respectively. During the quarter Jan-Mar, 2026, 09 more CIRPs was reported as yielding resolution plan, pertaining to the prior period, as presented in Part A of Table 5. 36 CIRPs yielded resolution plans during the quarter Jan-Mar, 2026, the details of which are presented in Part B of Table 5. 02 CDs which had earlier yielded resolution have since either moved into liquidation or the process has been ordered to be restarted, taking the total resolution plans approved to 1419 till March, 2026.

16 31 Jaiprakash Associates Limited

03-06-2024 17-03-2026 FC 60636.82 15799.00 19234.00 14084.20 23.23 89.15 73.23% 32 Redkenko Health Tech Private Limited Yes 16-12-2024 20-03-2026 FC 25.68 0.08 0.11 3.90 15.18

33 Classic Corrugations Private Limited No 09-01-2025 18-03-2026 OC 14.60 7.84 10.83 7.07 48.40 90.10 65.29% 34 Shubhada Tool Industries Private Limited Yes 17-01-2025 24-03-2026 FC 58.13 9.09 13.13 9.38 16.13 103.16 71.38% 35 Hridaynath Consultancy Private Limited

20-01-2023 09-03-2026 FC

36 Sabve Rohini Contractors Private Limited

27-03-2025 24-03-2026 FC

Total (Jan-Mar, 2026) 77564.95 17790.38 21946.43 17659.42 22.77% 99.26% 80.47% Total (Till March, 2026) 14,13,662.82 2,58,904 3,88,827 4,31,987.12 30.56 166.85 94.56% Notes: 1. CIRPs in 50 matters which yielded resolution plans and were reported earlier in this table have since moved into liquidation. The CIRPs have restarted in 30 cases and CIRPs in 19 matters, where liquidation orders were passed earlier, have yielded resolution plans. 2.. During the quarter, there are 9 CIRPs where the realisable value was less than the liquidation value of the CD. While realisable value is significantly influenced by the value of asset of the CD while entering the resolution process and time taken for resolution, it is also the outcome of a market determined price discovery process and commercial wisdom of the CoC.

• Based on 1298 cases where fair value has been estimated. NA: Not available Till March, 2026, the creditors have realised Rs. 4.32 lakh crore under the resolution plans. The fair value and liquidation value of the assets available with these CDs, when they entered the CIRP, was estimated at Rs. 3.89 lakh crore and Rs. 2.59 lakh crore, respectively, as against the total claims of the creditors worth Rs. 14.14 lakh crore. The creditors have realised 166.85% of the liquidation value and 94.56% of the fair value (based on 1298 cases where fair value has been estimated). The haircut for creditors relative to the fair value of assets was around 5%, while relative to their admitted claims is around 69%. Furthermore, this realisation does not include the CIRP cost, and many probable future realisations such as equity, realisation from corporate and personal guarantees, funds infused into the CD including capital expenditure by the resolution applicants, and recovery from avoidance applications. About 42% of the CIRPs (585 out of 1391 for which data are available), which yielded resolution plans, were earlier with BIFR and/or defunct. In these CDs, the claimants have realised 17.49% of their admitted claims and 174.03% of liquidation value. The remaining 58% of the CIRPs which yielded resolution plans, were not defunct at the time of commencement of CIRP. In these CDs, the claimants have realised 33.91% of their admitted claims and 171.43% of liquidation value. C.4.2 Resolution of Large Cases (Admitted Claims > Rs. 1000 crore) Of the 1419 CDs rescued under the Code as on March 31, 2026, 200 had admitted claims of more than Rs. 1,000 crore. The realisable value of the assets available with these 200 CDs, when they entered the CIRP, was only Rs. 2.22 lakh crore, though they owed Rs. 12.21 lakh crore to the creditors. Till March, 2026, realisation by the claimants under resolution plans in comparison to liquidation value is 172.64%, while the realisation by them in comparison to their claims is 31.41%. These realisations are exclusive of realisations that would arise from value of equity holdings post-resolution, resolution of PGs to CDs, and from disposal of applications for avoidance transactions. The details are presented in Table 6. Table 6: Details of resolution of large cases as on March 31, 2026 (Amount in Rs. lakh crore) CIRP cases (Admitted Claims > ` 1,000 crore) Till Dec, Jan - Total as 2025 Mar, on March 2026 31, 2026 Resolution No. of Cases 193 7 200 plans Admitted Claims 11.47 0.74 12.21 approved Liquidation Value 2.05 0.17 2.22 Realisation by creditors 3.67 0.16 3.83 Realisation by creditors as % 32.03 21.83 31.41 of Admitted Claims Realisation by creditors as % of 179.13 94.73 172.64 Liquidation Value C.4.3 Resolution of FiSPs CIRPs of four financial service providers (FiSPs) i.e. Dewan Housing Finance Corporation Ltd., Srei Equipment Finance Limited, Srei Infrastructure Finance Limited and Reliance Capital Ltd have yielded resolutions under the Code. The details of the resolutions are presented in Table 7. CIRP in the matter of AVIOM India Housing Finance Private Limited has been admitted vide order of AA dated February 20, 2025. Table 7: Details of resolution plans approved for FiSPs (Amount in Rs. crore) Sl. Claims of Financial Creditors Dealt Under Resolution Resolution Name of FiSP Amount Amount Realization Realisation Applicant Admitted Realized as % of as % of admitted Liquidation claims value 1 Dewan Housing 87247.68 37167.00 42.60% 138.42% Piramal Capital Finance & Housing Corporation Ltd Finance Ltd. 2 Srei Equipment 33050.43 13784.76 42.12% 280.74% National Asset Finance Limited Reconstruction Company Ltd. 3 Srei Infrastructure Finance Limited 4 Reliance Capital 26088.97 9661.00 37.03% 73.42% IndusInd Ltd International Holdings Ltd.

17 C.5 Withdrawals under Section 12A Till March 2026, a total of 1292 CIRPs have been withdrawn under section 12A of the Code. The reasons for withdrawal and distribution of claims in these CIRPs are presented in Figures 8 and 9. Almost three-fourth of these CIRPs had claims of less than Rs. 10 crore. Figure 8: Reasons for Withdrawal of CIRPs Figure 9: Distribution of CIRPs Withdrawn (as per Admitted Claims) C.6 Liquidation C.6.1 Overall outcomes Till FY 2024-25, a total of 2758 CIRPs had yielded orders for liquidation, of which the final reports were submitted in 1374 cases. Till December, 2025 2952 CIRPs ended with order of liquidation, of which the final reports were submitted in 1613 cases. During the quarter January-March 2026, 04 more CIRP were reported as yielding orders for liquidation, pertaining to the prior period. 01 case which had earlier ended in liquidation, has now yielded resolution plan. Further, 48 CIRPs ended in orders for liquidation during the current quarter, taking the total CIRPs ending in 64 58 430 295 445 Full settlement with the applicant Full settlement with other creditors Agreement to settle in future Other settlements with creditors Others liquidation to 3003. Of these, final reports have been submitted in 1692 cases. Till March 2026, 3003 CIRPs have ended in liquidation. Of 3003 CDs ending up with orders for liquidation, 228 had admitted claims of more than Rs. 1,000 crore. These CDs had an aggregate claim of Rs. 10.30 lakh crore. However, they had assets, on the ground, valued only at Rs. 0.49 lakh crore. Of the 3003 CDs, 1692 CDs have been completely liquidated with submission of final report. The overview of closed liquidation processes and timeline of ongoing 1311 cases is presented in Table 8 and Figure 10 respectively. CD-wise details of liquidation processes closed during this quarter are presented in Table 9. Table 8: Mode of Closure of Liquidation Processes Status of Liquidation Till Dec, Jan - Mar, Total as 2025 2026 on Mar 31, 2026 Initiated 2955 48 3003 Final Report submitted 1653 39 1692 Closed by Dissolution 909 32 941 Closed by Going Concern Sale 175 5 180 Closed by Compromise / Arrangement 16 1 17 Ongoing processes 1302 9 1311 Total Closed cases (A+B+C) 1100 38 1138 Total Admitted Claims (In Rs. crore) 327539.86 4905.55 332445.41 Liquidation Value (In Rs. crore) 15509.94 468.76 15978.70 Total Realisation (In Rs. crore) 12608.01 403.89 13011.90 *This excludes 50 cases where liquidation order has been set aside by NCLT / NCLAT / HC / SC. Figure 10: Timeline: Ongoing Liquidations

18 Table 9: Details of closed Liquidations (Amount in Rs. crore) Sl. Name of the Corporate Person Date of Amount of Liquidation Sale Amount Date of Order Order of Admitted Value Proceeds Distributed to of Dissolution/ Liquidation Claims Stakeholders Closure Part A: Reported for Prior Period (Till December, 2025) 1 East Coast Energy Private Limited 22-04-19 5641.35 306.37 273.53 223.00 16-10-24 2 Toshniwal Enterprises Control Limited 04-04-22 112.69 1.53 0.00 0.00 20-12-24 3 Sab Global Entertainment Media Private Limited 09-12-22 212.19 0.00 1.66 1.00 02-07-25 4 Rp Telebuy Skyshop Private Limited 22-11-23 52.17 0.05 0.38 0.18 26-09-25 5 Aegan Industries Private Limited 06-07-18 117.55 63.25 47.82 47.51 30-10-25 6 Aegan Batteries Limited 06-07-18 111.07 37.78 37.63 37.37 30-10-25 7 Champalal Motilal Steel Company Private Limited 02-05-22 189.39 0.05 0.05 0.00 20-11-25 8 Green India Building Systems & Services Private Limited 05-03-25 0.00 0.01 0.15 0.00 20-11-25 9 North American Mercantile India Private Limited 14-10-24 22.62 0.00 1.74 1.35 08-12-25 10 Mcchem-Anlagen Energies & Infratech Private Limited 14-09-22 1.25 0.52 0.30 0.01 19-12-25 Part B: For Jan-Mar, 2026 1 Prana Studios Private Limited 02-07-24 0.00 0.02 0.00 0.00 05-01-26 2 Ssb Structural & Galvanising Private Limited 19-09-24 18.22 0.00 0.02 0.00 09-01-26 3 Associated Cylinders And Accessories Private Limited 16-07-18 8.20 3.72 4.24 3.51 12-01-26 4 Akr Home Depot Private Limited 19-08-19 0.00 0.00 0.12 0.00 13-01-26 5 Ebc Bearings (India) Ltd 25-09-23 0.00 0.18 0.25 0.00 20-01-26 6 Bajrang Cotgin Private Limited 04-07-22 32.89 4.76 7.01 6.66 21-01-26 7 Octopus Papers Limited 21-12-22 46.55 3.20 4.39 3.79 21-01-26 8 Adelson Pharma Private Limited 12-10-23 0.36 0.00 0.00 0.00 21-01-26 9 Rudrasiva Infracon Pvt. Ltd. 19-06-23 0.00 0.61 0.00 0.00 22-01-26 10 Nippon Alloy Limited 08-12-20 344.93 42.93 61.92 60.42 29-01-26 11 Scotts Garments Limited 31-10-23 1214.49 130.88 62.86 59.18 29-01-26 12 Vipul-S Plastocrafts Private Limited 23-11-23 0.00 12.59 0.68 0.00 29-01-26 13 Pooja Soya Industries Private Limited 22-01-25 0.00 0.07 0.04 0.00 30-01-26 14 Neocortex Life Sciences Private Limited 22-07-25 0.00 0.01 0.01 0.00 04-02-26 15 Orient Newsprint Limited 13-03-24 0.00 0.00 0.00 0.00 06-02-26 16 Beckhem Trading Private Limited 24-10-24 0.00 0.00 0.00 0.00 09-02-26 17 Sintra Limited 15-07-22 0.53 2.56 1.53 0.14 12-02-26 18 Viswatma Merchandise Private Limited 27-07-23 106.17 1.94 1.84 1.46 12-02-26 19 Hi Tech Air Power Private Limited 03-02-25 0.00 0.03 0.06 0.00 17-02-26 20 Sri Venkatesa Paper & Board Private Limited 13-02-23 284.31 0.00 0.00 0.00 18-02-26 21 Sunlight Extrusion Private Limited 12-07-21 37.47 6.90 9.00 7.89 20-02-26 22 Doshion Water Umbrella (Cuddalore) Private Limited 13-09-23 165.26 0.49 0.66 0.35 20-02-26 23 Kavan Cotton Private Limited 29-04-24 0.00 0.10 0.24 0.00 21-02-26 24 Ajit Solar Private Limited 11-09-24 21.24 4.64 0.84 0.08 24-02-26 25 Mark Infrastructure Private Limited 13-07-23 0.00 7.44 0.01 0.00 26-02-26 26 Sudha Siva Traders Private Limited 12-09-24 0.00 0.00 0.09 0.00 02-03-26 27 Sagar Infra Rail International Limited 04-03-21 692.77 18.28 23.94 22.15 03-03-26

19 28 Planet ‘M’ Retail Limited 09-10-23 0.00 0.00 0.00 0.00 09-03-26 29 Bangalore Dehydration And Drying Equipment Co Private Limited 08-12-21 76.91 39.55 38.60 35.60 12-03-26 30 B T & F C Private Limited 08-12-21 76.91 39.55 38.60 35.60 12-03-26 31 Nadia Constructions Private Limited 24-06-25 0.00 0.00 2.65 0.00 12-03-26 32 Flora Footwear Private Limited 03-09-19 69.85 6.28 7.51 6.91 16-03-26 33 Cape Engineers Private Limited 25-04-22 37.13 0.77 2.95 2.25 18-03-26 34 Virar Fabrics Private Limited 02-08-22 0.00 0.00 0.07 0.00 24-03-26 35 Gena Pharmaceuticals Private Limited 07-01-22 141.94 8.87 4.67 3.63 25-03-26 36 Pps Enviro Power Private Limited 24-12-21 688.57 80.87 74.82 65.58 26-03-26 37 Gati Infrastructure Bhasmey Power Private Limited 06-12-24 840.85 48.93 54.28 51.18 26-03-26 38 Malola Management Consulting Services Private Limited 04-06-25 0.00 0.00 0.00 0.00 26-03-26 Note: ‘-’ means no value; 0 means an amount below two decimals NA means Not Applicable (Amount in Rs. crore) Sl. Name of the Corporate Person Date of Amount of Liquidation Sale Amount Date of Order Order of Admitted Value Proceeds Distributed to of Dissolution/ Liquidation Claims Stakeholders Closure Around 78% of the CIRPs ending in liquidation (2311 out of 2954 for which data are available) were earlier with BIFR and/or defunct. The economic value in most of these CDs had almost completely eroded even before they were admitted into CIRP. These CDs had assets, on average, valued at around 5% of the outstanding debt amount. C.6.2 Reasons for liquidation The AA passes an order for liquidation under four circumstances. As on March 2026, 3003 orders for commencement of liquidation have been passed. The details of liquidation in these circumstances are presented in Figure 11. Figure 11: Reasons for Liquidations C.6.3 Claims in liquidation process Regulation 12 of the Liquidation Regulations requires the liquidator to make a public announcement calling upon stakeholders to submit their claims as on the liquidation commencement date (LCD), within 30 days from the LCD. The details of the claims admitted by the liquidators in 2952 liquidations, for which data are available, are presented in Table 10. 2293 591 62 57 Table10: Claims in Liquidation Process (Amount in Rs. crore) Stakeholders Number Amount of Liquidation Amount Amount under Section of Claims Value Realised Distributed Claimants Admitted 1692 Liquidations where Final Report Submitted 52 94 10819.68 668.74 669.63 660.92 53 (1) (a) NA NA 21120.91 18243.14 3437.20 53 (1) (b) 13758 3,37,147.87 14,022.78 53 (1) (c) 10836 361.36 19.26 53 (1) (d) 2956 85713.72 445.25 53 (1) (e) 2008 26945.07 75.67 53 (1) (f) 28559 22486.90 183.2 53 (1) (g) 9 184.41 0 53 (1) (h) 324 2249.68 43.40 Total (A) 58544 485908.69 21789.65 18912.77 18887.68 Ongoing 1311 Liquidations* 53 (1) (a) NA NA 53 (1) (b) 36621 610910.23 53 (1) (c) 29594 1272.20 53 (1) (d) 11265 120166.25 53 (1) (e) 2394 30521.39 50789.78 NA NA 53 (1) (f) 1965068 81900.06 53 (1) (g) 46 563.51 53 (1) (h) 105521 2435.52 Total (B) 2150509 847769.2 Grand Total (A+B) 2209053 1333678 72579.43

Inclusive of unclaimed proceeds of Rs.25.09 crore under liquidation.

• Out of 1311 ongoing cases, liquidation value of only 1088 CDs is available. Liquidation value of 642 CDs taken during liquidation process is Rs.35,534.79 crore and liquidation value of rest of the 446 CDs captured during CIRP is Rs.15,254.99 crore.

20 C.6.4 Sale as Going Concern Till March, 2026, 180 CDs were closed by sale as a going concern under liquidation process. These 180 CDs had claims amounting to Rs. 213289.88 crore, as against the liquidation value of Rs. 9668.62 crore. The liquidators in these cases realized Rs. 7198.32 crore and companies were rescued. C.7 Voluntary Liquidation C.7.1 Overview A corporate person may initiate voluntary liquidation proceeding if majority of the directors or designated partners of the corporate person make a declaration to the effect that (i) the corporate person has no debt or it will be able to pay its debts in full, from the proceeds of the assets to be sold under the proposed liquidation, and (ii) the corporate person is not being liquidated to defraud any person. Till March, 2025, 2211 corporate persons initiated voluntary liquidation of which final reports were submitted in 1680 cases and 44 cases were withdrawn. At the end of March, 2026, 2619 corporate persons initiated voluntary liquidation, of which final reports have been submitted in 2022 cases. Further, 44 processes have been withdrawn by March 31, 2026. The details of commencement of voluntary liquidations are presented in Table 11. The timeline of ongoing voluntary liquidations is presented in Figure 12. Table 11: Commencement of Voluntary Liquidations till March 31, 2026 (Number) Period Liquidations Liquidations Liquidation closed by Liquidations at the Commenced Withdrawal Final at the end beginning Reports of period Submitted 2017 – 18 0 184 0 11 173 2018 – 19 173 232 7 108 290 2019 – 20 290 273 1 170 392 2020 – 21 392 250 2 187 453 2021 – 22 453 303 3 260 493 2022 – 23 493 320 9 335 469 2023 – 24 469 336 12 341 452 2024 - 25 452 384 10 331 495 Apr–Jun, 2025 495 62 0 97 460 Jul-Sep, 2025 460 77 0 74 463 Oct-Dec, 2025 463 72 0 63 472 Jan-Mar, 2026 472 126 0 45 553 Total NA 2619 44 2022 553 Figure 12: Timeline of Ongoing Voluntary Liquidations Of the 2619 corporate persons that initiated voluntary liquidations (excluding withdrawals) till March 31, 2026, the reasons for these initiations are available for 2560 cases, which are presented in Figure 13. Most of these corporate persons are small entities. 1611 of them have paid-up equity capital of less than or equal to Rs. 1 crore. Only 372 of them have paid-up capital exceeding Rs. 5 crore. The corporate persons, for which details are available, have an aggregate paid-up capital of Rs. 18,454 crore (Table 12). Figure 13: Reasons for Voluntary Liquidation Table 12: Details of Voluntary Liquidations (Excluding Withdrawals) Details of No. of Amount (in Rs. crore) Liquid- Paid-up Assets Out- Amount Surplus ations capital* standing paid to debt creditors Liquidations for which 2022 11489.61 13564.00 2928.90 2928.90 13215.87 Final Reports submitted** Ongoing Liquidations 553 6737.21 4932.47# *** Total 2575 18226.82 18496.47

---

Notes:

• Paid up capital is not available in case of thirteen companies as they are limited by guarantee companies where there exist no shareholders and paid-up capital. ** Data of 6 Final Report cases is awaited. *** For ongoing liquidations, data is not available

Assets of 485 cases are available.

21 C.7.2 Dissolution orders in voluntary liquidation It was reported in the last newsletter that dissolution orders were passed in respect of 1472 voluntary liquidations. Dissolution orders in respect of 15 more voluntary liquidations, which were issued during the earlier period, were reported later. During the quarter Jan-Mar, 2026 dissolutions orders in respect of 55 voluntary liquidations were issued taking the total dissolutions to 1542. These 1542 corporate persons owed Rs. 1800.27 crore to creditors and through voluntary liquidation process, they were paid full amount. Sl Name of Corporate Person Date of Date of Realisation Amount Amount Liquidation Surplus No. Commencement Dissolution of Assets due to paid to Expenses Creditors Creditors Part A: For Prior Period (Till December, 2025) 1 Ts Shape India Private Limited 16-06-23 15-04-24 0.43 0.38 0.38 0.05 0.00 2 Clementia Mining Private Limited 30-11-17 03-10-24 0.84 0.00 0.00 0.04 0.81 3 Datatorrent Software India Private Limited 03-02-20 08-05-25 1.15 1.03 1.03 0.12 0.00 4 Suntech Ceramics Private Limited 01-10-24 30-07-25 1.96 0.00 0.00 0.30 1.66 5 Ddms Simulations Software Consultants Private Limted 30-09-23 11-11-25 0.07 0.04 0.04 0.03 0.00 6 Hsm Consultants India Private Limited 21-06-24 11-11-25 3.86 0.40 0.40 3.45 0.00 7 Kinder Medical Services Private Limited 02-01-25 19-11-25 0.02 0.00 0.00 0.01 0.00 8 Skandysys Private Limited 20-12-23 26-11-25 5.16 0.00 0.00 0.09 5.06 9 Madhu Business Services Private Limited 07-12-24 26-11-25 0.63 0.59 0.59 0.05 0.00 10 Pramati Software Private Limited 03-07-24 28-11-25 41.20 0.00 0.00 0.35 40.85 11 Rooters Mobility Private Limited 22-08-23 12-12-25 0.09 0.00 0.00 0.04 0.05 12 Talin Kitchen Solutions Private Limited 01-03-25 12-12-25 0.04 0.00 0.00 0.04 0.00 13 Talin Interior Private Limited 01-03-25 12-12-25 0.06 0.00 0.00 0.06 0.00 14 Talin Consultancy Services Private Limited 01-03-25 12-12-25 0.06 0.00 0.00 0.06 0.00 15 Esteem Credits And Investments Private Limited 29-03-25 16-12-25 1.22 1.19 1.19 0.03 0.00 Part B: For January-March, 2026 1 Bias It Consulting Private Limited 31-03-22 06-01-26 2.61 1.56 1.56 0.00 1.05 2 Asocietyconsulting India Private Limited 13-07-24 06-01-26 0.31 0.28 0.28 0.03 0.00 3 Simplicity Foods And Beverages Private Limited 15-03-25 06-01-26 4.04 3.98 3.98 0.05 0.00 4 Whizdotai India Private Limited 18-09-25 07-01-26 34.70 34.53 34.53 0.17 0.00 5 Paras Barter Private Limited 03-08-24 08-01-26 8.49 0.00 0.00 0.05 8.43 6 Srianagha Sky Scrapers Private Limited 17-01-22 08-01-26 0.08 0.00 0.00 0.08 0.00 7 Ravi Cotton Factory Private Limited 05-08-24 08-01-26 1.69 1.65 1.65 0.04 0.00 8 Mira India Management Services Private Limited 30-09-24 08-01-26 0.33 0.30 0.30 0.03 0.00 9 S.Oliver Fashion India Private Limited 29-03-25 08-01-26 2.34 0.02 0.02 0.20 2.12 10 Rajat Holdings Pvt. Ltd. 03-10-23 13-01-26 0.22 0.00 0.00 0.01 0.21 11 National Centre For Trade Information 26-11-21 13-01-26 5.60 4.86 4.86 0.73 0.00 12 Vins Monofil Private Limited 28-03-24 13-01-26 0.12 0.00 0.00 0.03 0.09 13 G. Nandy Industries Private Limited 23-09-24 13-01-26 0.04 0.02 0.02 0.02 0.00 14 Janpath Restaurants Private Limited 09-03-22 20-01-26 0.03 0.03 0.03

0.00 15 Srj Poly Films Private Limited 06-01-25 20-01-26 4.52 0.00 0.00 0.03 4.49 16 Batwings Learning Centers Private Limited 10-09-24 22-01-26 0.00 0.00 0.00 0.00 0.00 17 Sentinal Capital Limited 25-08-25 27-01-26 0.05 0.02 0.02 0.03 0.00 18 Jenbacher Distributed Power India Private Limited 03-04-25 29-01-26 0.13 0.00 0.00 0.13 0.00 Table 13: Realisations under Voluntary Liquidations (Amount in Rs.crore)

22 Sl Name of Corporate Person Date of Date of Realisation Amount Amount Liquidation Surplus No. Commencement Dissolution of Assets due to paid to Expenses Creditors Creditors 19 Equalize Health India Private Limited 21-08-23 30-01-26 0.16 0.00 0.00 0.16 0.00 20 Pipecandy Technologies Private Limited 31-05-24 30-01-26 0.00 0.00 0.00 0.00 0.00 21 Marmalade Digital Private Limited 24-01-25 30-01-26 2.42 0.00 0.00 0.09 2.33 22 Nagwa India Private Limited 12-03-25 05-02-26 0.33 0.28 0.28 0.05 0.00 23 Oiltanking Infrastructure Services Private Limited 01-10-25 05-02-26 0.06 0.00 0.00 0.06 0.00 24 Cango Networks Private Limited 16-01-23 06-02-26 16.39 0.00 0.00 5.04 11.34 25 Terracotta Software India Private Limited 22-01-25 06-02-26 0.00 0.00 0.00 0.00 0.00 26 Vinayak Services Private Limited 05-06-25 10-02-26 2.78 2.75 2.75 0.04 0.00 27 Agarwal Commodities Broker Private Limited 03-02-25 12-02-26 1.20 1.20 1.20 0.00 0.00 28 Icp Industrial Coatings India Private Limited 08-04-24 17-02-26 1.43 0.00 0.00 0.06 1.37 29 Professional Ventures Private Limited 14-02-24 20-02-26 7.98 7.94 7.94 0.04 0.00 30 Dpa Technologies Private Limited 21-08-24 20-02-26 0.48 0.40 0.40 0.08 0.00 31 Axio Capital Private Limited 31-03-25 20-02-26 11.49 0.00 0.00 11.49 0.00 32 Coincept Accounting Solutions Private Limited 30-03-25 20-02-26 1.31 1.04 1.04 0.27 0.00 33 Delcam Consulting And Technology Services Private Limited 24-09-19 23-02-26 2.73 2.71 2.71 0.02 0.00 34 Playspan India Private Limited 31-03-21 24-02-26 7.98 0.02 0.02 0.40 7.56 35 Kiepe Electric India Private Limited 08-07-24 24-02-26 0.83 0.00 0.00 0.83 0.00 36 Vital Technical India Private Limited 18-03-24 24-02-26 4.42 4.37 4.37 0.05 0.00 37 Ing Bpo Services India Private Limited 04-03-24 27-02-26 0.64 0.00 0.00 0.64 0.00 38 Mso Hospitality And Tourism Private Limited 22-10-24 27-02-26 3.73 3.33 3.33 0.39 0.00 39 A-Sonic Express Logistics (India) Private Limited 21-11-24 27-02-26 0.03 0.02 0.02 0.01 0.00 40 47Line Technologies Private Limited 20-12-21 27-02-26 0.52 0.46 0.46 0.06 0.00 41 Suburban Diagnostics (India) Private Limited 06-02-25 27-02-26 977.10 976.90 976.90 0.20 0.00 42 Magizham Nidhi Limited 30-09-24 02-03-26 0.30 0.27 0.27 0.03 0.00 43 Spicaworks India Private Limited 20-12-23 04-03-26 2.77 0.01 0.01 0.23 2.54 44 Tulsiimpex Forwarders Private Limited 24-10-24 06-03-26 0.64 0.00 0.00 0.04 0.60 45 Quiet Platforms India Private Limited 28-03-25 06-03-26 0.35 0.35 0.35 0.01 0.00 46 Royal Hire Purchase Private Limited 11-02-25 11-03-26 1.97 1.91 1.91 0.06 0.00 47 Lxtech India Private Limited 03-04-25 12-03-26 0.00 0.00 0.00 0.00 0.00 48 Aquagel Chemicals (Bhavnagar) Private Limited 29-01-25 13-03-26 10.17 10.04 10.04 0.13 0.00 49 Micello (India) Private Limited 10-04-23 25-03-26 0.17 0.00 0.00 0.09 0.08 50 Toolbox Technologies Private Limited 13-07-24 26-03-26 3.95 0.00 0.00 0.03 3.92 51 Chakra Dealtrade Private Limited 21-02-25 26-03-26 7.92 7.90 7.90 0.02 0.00 52 Aecio It Solutions India Private Limited 18-03-25 27-03-26 2.36 2.19 2.19 0.16 0.00 53 Numans Technologies Private Limited 01-10-24 30-03-26 1.07 1.04 1.04 0.03 0.00 54 Pharmaspectra Informatics Private Limited 31-01-25 30-03-26 12.77 12.57 12.57 0.21 0.00 55 Aliceblue Insurance Broking Private Limited 12-10-23 30-03-26 1.12 1.09 1.09 0.03 0.00 (Amount in Rs. crore) Notes: ‘0’ means an amount below two decimals; ‘-’ means no value

Data awaited

23 C.8 Corporate Liquidation Accounts The Regulations require a Liquidator to deposit the amount of unclaimed dividends, if any, and undistributed proceeds, if any, in a liquidation process along with any income earned thereon into the corporate liquidation account before he submits an application for dissolution of the corporate person. It also provides a process for a stakeholder to seek withdrawal from the said account. Similar provisions exist for voluntary liquidation processes. The details of these accounts at the end of March 2026 are presented in Table 14. Table 14: Corporate Liquidation Accounts as on March 31, 2026 (Amount in Rs.lakh) Name of Account Opening Deposit Withdrawn Balance at Balance during during the end of the period the period the period Corporate Liquidation Account 2019 – 20 0.00 476.26 0.21 476.05 2020 – 21 476.05 116.18 0.00 592.23 2021 – 22 592.23 25.94 4.84 613.33 2022 – 23 613.33 596.10 0.00 1209.43 2023 – 24 1209.43 777.37 9.26 1977.54 2024 - 25 1977.54 755.17 3.17 2729.54 Apr - Jun, 2025 2729.54 19.79 19.06 2730.27 Jul- Sep, 2025 2730.27 1.69 299.46 2432.50 Oct-Dec, 2025 2432.50 69.94 0.00 2502.44 Jan-Mar, 2026 2502.44 11.796 0.00 2514.24 Corporate Voluntary Liquidation Account 2019 – 20 0.00 109.70 0.00 109.70 2020 – 21 109.70 112.07 0.00 221.77 2021 – 22 221.77 127.94 0.03 349.68 2022 – 23 349.68 241.30 10.42 580.56 2023 – 24 580.56 265.49 39.02 807.03 2024 - 25 807.03 166.49 17.50 956.02 Apr - Jun, 2025 956.02 135.57 2.74 1088.85 Jul- Sep, 2025 1088.85 109.01 0.00 1197.86 Oct-Dec, 2025 1197.86 1054.98 0.00 2252.84 Jan-Mar, 2026 2252.84 4.26 0.40 2256.69 C.9 Pre-Packaged Insolvency Resolution Process The Central Government enacted the Insolvency and Bankruptcy Code (Amendment) Act, 2021 on August 11, 2021 which was deemed to have come into force on April 4, 2021 introducing the Pre-packaged Insolvency Resolution Process (PPIRP) for corporate MSMEs. On April 9, 2021, the Central Government notified the Insolvency and Bankruptcy (Pre-packaged Insolvency Resolution Process) Rules, 2021 prescribing the manner and form of making application to initiate PPIRP and the IBBI notified the IBBI (Pre-packaged Insolvency Resolution Process) Regulations, 2021. The Regulations provide for manner of carrying out certain processes and tasks under PPIRP. As per the information available with the Board, 18 applications have been admitted as on March 31, 2026, out of which one has been withdrawn and resolution plans has been approved in ten cases i.e., Amrit India Limited, Sudal Industries Limited, Shree Rajasthan Syntex Limited, Enn Tee International Limited, GCCL Infrastructure and Projects Limited, Mudraa Lifespaces Private Limited, Garodia Chemicals Limited, Kvir Towers Private Limited, Rg Residency Private Limited and Kratos Energy & Infrastructure Limited. The details of the ongoing cases are in Table 15. Table 15: List of ongoing cases for PPIRP as on March 31, 2026 Sl. Name of the CD Date of Name of the admission NCLT Bench 1. Kethos Tiles Private Limited 04-01-24 Ahmedabad 2. Shreemati Fashions Private Limited 05-01-24 Kolkata 3. G Security (India) Private Ltd 10-12-24 Mumbai 4. Vedik Ispat Private Limited 05-02-25 Bengaluru 5. Medhansh Snacks Private Limited 08-08-25 New Delhi 6. Sab Events & Governance Now Media Limited 04-11-25 Mumbai 7. Ramdurlabhpur Tea Co Limited 01-12-25 Kolkata C. 10 Avoidance Transactions The Code read with Regulations requires the RPs and Liquidators to file applications for avoidance of transactions, with the AA seeking appropriate directions. 1878 applications seeking avoidance of transactions have been filed with the AA till March 31, 2026 as presented in Table 16. Table 16: Details of avoidance applications filed (Amount in Rs. crore) Sl. Nature of transactions Applications Filed Number of transactions Amount involved 1 Preferential 319 36,449.93 2 Undervalued 89 3,967.43 3 Fraudulent 653 1,43,424.11 4 Extortionate 8 96.41 5 Combination 809 2,54,231.19 Total 1878 4,38,169.07 D. Individual Processes D.1 Insolvency Resolution Process The provisions relating to insolvency resolution and bankruptcy relating to PGs to CDs came into force on December 1, 2019. As per the information received from the applicants, IPs, and data collected from various benches of NCLT and Debt Recovery Tribunal (DRT), 4941 applications have since been filed as of March 31, 2026, for initiation of personal insolvency resolution process (PIRP) of PGs to CDs. Out of them, 885 applications have been filed by the debtors and 4056 applications by the creditors under sections 94 and 95 of the Code, respectively. Among them 51 have been filed before different benches of Debt Recovery Tribunal (DRT) and 4890 have been filed before different benches of NCLT (Table 17).

24 Table 17: Insolvency Resolution of Personal Guarantors (Amount in Rs. crore) Period Applications filed by Total Adjudicating Number of Authority cases where Debtors Creditors NCLT DRT RPs have been (u/s 94) (u/s 95) appointed 2019 - 20 4 23 27 26 1 2 2020 - 21 27 255 282 276 6 35 2021 - 22 88 961 1049 1034 15 469 2022 - 23 88 909 997 996 1 557 2023 - 24 250 587 837 810 27 595 2024 - 25 173 892 1065 1064 1 232 Apr-Jun, 2025 50 114 164 164 0 51 Jul-Sep, 2025 71 113 184 184 0 2 Oct-Dec, 2025 28 94 122 122 0 33 Jan-Mar, 2026 106 108 214 214 0 93 Total 885 4056 4941 4890 51 2069 Note: The data are provisional. These are revised on a continuous basis as further information is received. Of these, 44 cases have yielded approval of repayment plan. In cases where repayment plans have been approved, the creditors have realised Rs.102.78 crore, which is 2.16% of their admitted claims. D.2 Bankruptcy Process If the resolution process fails or repayment plan is not implemented, the debtor or the creditor may make an application for initiation of the bankruptcy process. As per the information received from the applicants, IPs and data collected from various benches of NCLT and DRT, bankruptcy applications have been filed in respect of 253 PGs to CDs, as of March 2026. E. Service Providers E.1 Insolvency Professionals An individual, who is enrolled with an IPA as a professional member and has the required qualification and experience and passed the Limited Insolvency Examination, is registered as an IP. Pursuant to the IBBI (Insolvency Professionals) (Fourth Amendment) Regulations, 2022 read with IBBI (Model Byelaws and Governing Board of Insolvency Professional Agencies) (Amendment) Regulations, 2022, the Insolvency Professional Entities (IPEs) have been permitted to registered as IP to carry on the activities of an IP. An IP needs an authorization for assignment (AFA) to take up an assignment under the Code with effect from January 1, 2020. The IBBI made available an online facility from November 16, 2019, to enable an IP to make an application for issuance/renewal of AFA to the concerned IPA. Thereafter, an IPA processes such applications electronically. The details of IPs registered as on March 31, 2026, and AFAs held by them, IPA-wise, are presented in Table 18. Table 18: Registered IPs and AFAs as on March 31, 2026 (Number) City / Region Registered IPs IPs having AFA IIIP ICSI IPA of Total IIIP ICSI IPA of Total ICAI IIP ICMAI ICAI IIP ICMAI New Delhi 513 299 97 909 212 143 42 397 Rest of Northern Region 534 224 94 852 201 96 31 328 Mumbai 449 158 44 651 184 69 15 268 Rest of Western Region 395 148 61 604 186 73 23 282 Chennai 161 92 25 278 59 39 12 110 Rest of Southern Region 462 245 99 806 161 103 44 308 Kolkata 251 46 29 326 123 19 18 160 Rest of Eastern Region 82 38 12 132 29 19 6 54 Total (Individual) 2847 1250 461 4558 1155 561 191 1907 Total (IPE as IP) 55 17 26 98 45 13 18 76 Grand Total 2902 1267 487 4656 1200 574 209 1983 Of the 4637 IPs registered till date, registrations of 15 IPs have been cancelled through disciplinary action, and registrations of 28 IPs cancelled on failing to fulfil the requirement of fit and proper person status. As per information available, 36 IPs have passed away. The registrations and cancellations of registrations IPs, quarter wise, till March 31, 2026 are presented in Table 19. Table 19: Registration and Cancellation of Registration of IPs (Number) Year / Quarter Regis- Registered Cancelled during the Registered tered during the period on account of at the at the period Discip- Failing to fulfil Dea- end of beginning linary the continuing th the of the Process requirement of period period ‘fit and proper person’ status 2016-17 (Nov-Dec)# 0 977 0 0 0 977 2016-17 (Jan-Mar) 0 96 0 0 0 96 2017 – 18 96 1716 0 0 0 1812 2018 – 19 1812 648 4 0 0 2456 2019 – 20 2456 554 0 1 5 3004 2020 – 21 3004 506 0 1 5 3504 2021 – 22 3504 549 1 0 8 4044 2022 – 23 4044 209 2 0 5 4246 2023 – 24 4246 116 3 0 7 4352 2024 - 25 4352 114 5 22 4 4435 Apr-Jun, 2025 4435 30 0 0 0 4465 Jul-Sep, 2025 4465 17 0 4 0 4478 Oct-Dec, 2025 4478 37 0 0 2 4513 Jan-Mar, 2026 4513 45 0 0 0 4558 Total (Individual) NA 4637 15 28 36 4558 Total (IPE as IP) NA 98 0 0 0 98 Grand Total NA 4735 15 28 36 4656

Registration with validity of six months. These registrations expired by

June 30, 2017.

25 An individual with 10 years of experience as a member of the ICAI, ICSI, ICMAI or a Bar Council or 10 years of experience in the field of law, after receiving a Bachelor’s degree in law or 10 years of experience in management, after receiving a Master’s degree in Management or two year full time Post Graduate Diploma in Management or 15 years of experience in management, after receiving a Bachelor’s degree is eligible for registration as an IP on passing the Limited Insolvency Examination. The Post Graduate Insolvency Programme (PGIP) is a first of its kind programme for those aspiring to take up the profession of IP as a career without having to wait for acquiring the specified 10/15 years of experience. The IBBI has granted approval to three institutes to conduct PGIP - the Indian Institute of Corporate Affairs, National Law Institute University, Bhopal and National Law University, Delhi. The IBBI has granted 50 registrations based on this qualification, until March 31, 2026. Table 20 presents distribution of IPs as per their eligibility (an IP may be a member of more than one Institute) as on March 31, 2026. Of the 4558 IPs (individual) as on March 31, 2026, 476 IPs (constituting about ten per cent of the total registered IPs) are female. Table 20: Distribution of IPs as per their Eligibility as on March 31, 2026 (Number) Eligibility No. of IPs (Individual) Male Female Total Member of ICAI 2248 231 2479 Member of ICSI 618 144 762 Member of ICMAI 186 19 205 Member of Bar Council 246 37 283 Managerial Experience 741 38 779 PGIP Qualified 43 7 50 Total 4082 476 4558 The Regulations provide that an IP (individual) shall be eligible to obtain an AFA if he has not attained the age of 70 years. Table 21 presents the age profile of the IPs registered as on March 31, 2026. Table 21: Age Profile of IPs (individual) as on March 31, 2026 (Number) Age Group Registered IPs IPs having AFA ( in Years) IIIP ICSI IPA of Total IIIP ICSI IPA of Total ICAI IIP ICMAI ICAI IIP ICMAI < 30 19 9 3 31 9 6 1 16

30 < 40 145 65 16 226 76 39 9 124 40 < 50 905 306 60 1271 388 145 23 556 50 < 60 861 399 99 1359 377 203 51 631 60 < 70 764 355 205 1324 305 168 107 580 70 < 80 147 107 75 329 NA NA NA NA 80 < 90 5 7 3 15 NA NA NA NA 90 1 2 3 NA NA NA NA Total 2847 1250 461 4558 1155 561 191 1907 NA: Not Applicable. E.2 Replacement of IRP with RP Section 22(2) of the Code provides that the CoC may, in its first meeting, by a majority vote of not less than 66% of the voting share of the FCs, either resolve to appoint the IRP as the RP or to replace the IRP by another IP to function as the RP. Under section 22(4) of the Code, the AA shall forward the name of the RP, proposed by the CoC, under section 22(3)(b) of the Code, to IBBI for its confirmation and shall make such appointment after such confirmation. However, to save time in such reference, a database of all the IPs registered with the IBBI has been shared with the AA, disclosing whether any disciplinary proceeding is pending against any of them and the status of their AFAs. While the database is currently being used by various Benches of the AA, in a few cases, the IBBI receives references from the AA and promptly responds to it. Till March 31, 2026, as per updates available, a total of 1924 IRPs have been replaced with RPs, as shown in Figure 14. It is observed that IRPs in about 35% of CIRPs initiated by CD are replaced by RPs, in 33% of CIRPs initiated by OCs and in 22% of CIRPs initiated by FCs. Figure 14: Replacement of IRP with RP E.3 Insolvency Professional Entities During the quarter under review, 1 entity was given recognition as IPE and 1 entity got de-recognised. As on March 31, 2026, there were 131 active IPEs (Table 22). Table 22: IPEs as on March 31, 2026 Quarter No. of IPEs Recognised Derecognised At the end of the Period 2016 - 17 (Jan – Mar) 3 0 3 2017 – 18 73 1 75 2018 – 19 13 40 48 2019 – 20 23 2 69 2020 – 21 14 0 83 2021 – 22 10 2 91 2022 – 23 17 1 107 2023 – 24 15 0 122 2024 - 25 7 2 127 Apr-Jun, 2025 0 0 127 Jul-Sep, 2025 0 0 127 Oct-Dec, 2025 1 1 127 Jan-Mar, 2026 5 1 131 Total 181 50 131

26 E.4 Insolvency Professional Agencies IPAs are front-line regulators and are responsible for developing and regulating the insolvency profession. They discharge three kinds of functions, namely, quasi-legislative, executive, and quasi- judicial. The quasi-legislative functions cover laying down standards and code of conduct through byelaws, which are binding on all members. The executive functions include monitoring, inspection, and investigation of professional members on a regular basis, addressing grievances of aggrieved parties, gathering information about their performance, etc., with the overarching objective of promoting best practices and conduct by IPs. The quasi-judicial functions include dealing with complaints against members and taking suitable disciplinary actions. As on March 31, 2026, there are three IPAs registered in accordance with the Code and Regulations. The IBBI interacts with the Managing Directors (MDs) of the IPAs regularly, to obtain feedback on areas of concern for the profession of IPs and discuss the status of resolutions and the way forward. Table 23 presents the details of activities by the IPAs. Table 24 gives details of number of continuing professional education (CPE) hours earned by IPs. Table 23: Activities by IPAs Period Number of Pre- CPE Training Other Discip- Compl- regist- Progra- Work- Work linary aints ration mmes shops shops/ Orders (Forwar- Courses cond- for IPs Webinars/ Issued ded by conducted ucted Roundtables/ IBBI) Seminars Disposed 2018 – 19 16

7 100 4 11 2019 – 20 11 30 9 157 9 127 2020 – 21 14 193 66 102 42 102 2021 – 22 13 133 56 81 23 12 2022 – 23 15 231 104 192 85 125 2023 – 24 3 198 61 135 49 179 2024 - 25 3 250 92 161 30 115 Apr - Jun, 2025 1 67 23 44 7 55 Jul-Sep, 2025 1 68 26 42 0 18 Oct-Dec, 2025 0 66 34 40 23 23 Jan-Mar, 2026 1 57 19 38 2 19 Total 78 1293 497 1092 274 786 Table 24: CPE Hours earned by the IPs Period Number of CPE Hours earned by members of IIIP ICAI ICSI IIP IPA ICAI Total 2019 - 20 1160 695 320 2175 2020 - 21 18465 8746 4647 31858 2021 - 22 14123 7890 3872 25885 2022 - 23 22185 10732 3433 36350 2023 - 24 5803 9835 3715 19353 2024 - 25 14240 9125 3635 27000 Apr-Jun, 2025 3552 2431 595 6578 Jul-Sep, 2025 3656 2499 931 7086 Oct-Dec, 2025 9051 4749 2000 15800 Jan-Mar, 2026 5076 3497 1041 9614 Total 97311 60199 24189 181699 Average CPE hours per registered IP 34.2 48.2 52.5 39.9 E.5 Information Utility The Code provides that the data with the IU facilitates the CIRP. The RoD of the IU provides evidence of debt and default and assists the AA in deciding on an application for admission of insolvency proceedings against a CD. Sections 7(3) & 9(3) of the Code read with the Insolvency and Bankruptcy (Application to Adjudicating Authority) Rules, 2016, require submission of RoD from an IU as evidence of default, among various other options, along with application for initiation of CIRP. The RoD issued by an IU has evidentiary value in IBC processes. It contains complete details of the parties to the debt, debt information, security details, default information, details of communication with debtor and authentication status by the counter parties of the debt categorized in accordance with regulation 21 of the IBBI (Information Utilities) Regulations, 2017. The IU issues RoD in every defaulted loan (unique debt) reported to it on completing the process of authentication. There is one IU, namely, the NeSL that provides authenticated financial information to the users. The IBBI interacts with the MD & CEO of the IU regularly to discuss the issues relating to receipt and authentication of financial information. At the end of March 2026, NeSL issued about 1,39,160 RoDs under Corporate Segment to support the IBC ecosystem. Figure 15 provides details of the registered users and information with NeSL, as submitted by it. Figure 15: Details of information with NeSL (Number in Lakhs) E.6 Registered Valuer Organisations The Companies (Registered Valuers and Valuation) Rules, 2017 (Valuation Rules) made under section 247 of the Companies Act, 2013 provide a unified institutional framework for development and regulation of valuation profession. Its remit is limited to valuations required under the Companies Act, 2013 and the Code. The IBBI performs the functions of the Authority under the Valuation Rules. It recognises Registered Valuer Organisations (RVOs) and registers RVs and exercises regulatory oversight over them, while RVOs serve as front-line regulators for the valuation profession. An individual having specified qualification and experience needs to enrol with an RVO, complete the educational course conducted by the RVO and clear the examination conducted by IBBI, before seeking registration with IBBI as an RV. There are currently 14 RVOs. The IBBI meets MDs / CEOs of RVOs every month to discuss the issues arising from the valuation profession, to resolve queries of the RVOs and to guide them in discharge of their responsibilities.

27 The details of individual RVs, RVO-wise, as on March 31, 2026, are given in Table 25. A total of 6108 individuals have active registrations, five of them are registered for all three asset classes, 103 are registered for two asset classes and the balance 5887 are registered for one asset class. As on March 31, 2026, the registration of sixteen RVs have been cancelled. Table 25: Registered Valuers as on March 31, 2026 (Number) Sl. Registered Valuer Organisation Asset Class Total Land & Plant & Securities Build- Machi- or Financial ing nery Assets 1 RVO Estate Managers and Appraisers Foundation 101 18 14 133 2 IOV: IOV Registered Valuers Foundation 1774 273 201 2248 3 ICSI: ICSI Registered Valuers Organisation 0 0 259 259 4 IIV India registered Valuers Foundation 218 51 58 327 5 ICMAI: ICMAI Registered Valuers Organisation 73 35 327 435 6 ICAI: ICAI Registered Valuers Organisation 3 1 1216 1220 7 PVAI: PVAI Valuation Professional Organisation 329 60 139 528 8 CVSRTA: CVSRTA Registered Valuers Association 194 59 0 253 9 CEV: CEV Integral Appraisers Foundation 175 47 3 225 10 DJF: Divya Jyoti Foundation 138 23 77 238 11 Nandadeep Valuers Foundation 8 0 1 9 12 IBVA: International Business Valuers Association 5 2 24 31 13 AIVA: All India Valuers Association 2 0 0 2 14 AaRVF: Assessors and Registered Valuers 114 31 55 200 foundation Total 3134 600 2374 6108 RVs are permitted to form an entity (Partnership / Company) for rendering valuation services. There are 133 such entities registered as RVE as on March 31, 2026, as presented in Table 26. 57 of them are registered for three asset classes, 28 are registered for two asset classes and 48 are registered for one asset class. The registration of RVs till March 31, 2026 is given in Table 27. Table 26: Registered Valuers (Entities) as on March 31, 2026 Registered Valuer Number Asset Class Organisation of Entities `Land & Plant & Securities Building Machinery or Financial Assets RVO Estate Managers and Appraisers 8 7 6 6 Foundation IOV Registered Valuers Foundation 48 39 34 37 ICSI Registered Valuers Organisation 5 1 1 5 IIV India Registered Valuers Foundation 3 3 3 2 ICMAI Registered Valuers Organisation 19 12 11 18 ICAI Registered Valuers Organisation 21 2 1 4 PVAI Valuation Professional Organisation 5 4 3 5 CVSRTA Registered Valuers Association 1 1 1 0 CEV Integral Appraisers Foundation 2 2 2 0 Divya Jyoti Foundation 6 5 2 6 All India Institute of Valuers Foundation 0 0 0 0 International Business Valuers Association 11 9 8 8 Nandadeep Valuers Foundation 2 1 1 1 Assessors and Registered Valuers foundation 2 1 1 2 Total 133 87 74 94 Table 27: Registration of RVs till March 31, 2026 (Number) Year / Quarter Land & Plant & Securities or Total Building Machinery Financial Assets 2017 – 18 0 0 0 0 2018 – 19 781 121 284 1186 2019 – 20 848 204 792 1844 2020 – 21 409 82 446 937 2021 – 22 302 67 303 672 2022 – 23 311 57 275 643 2023 – 24 138 23 89 250 2024-25 170 27 83 280 Apr-June, 2025 55 8 38 101 July-Sept, 2025 50 8 24 82 Sept-Dec, 2025 33 2 17 52 Jan-Mar, 2026 37 1 23 61 Total 3134 600 2374 6108* *Registration of 16 RVs have been cancelled. As on March 31, 2026, 1454 RVs (constituting 24% of the total RVs registered) are from metros, while 4654 RVs (constituting 76% of the total RVs registered) are from non-metro locations. The region-wise detail of RVs is given in Table 28. Table 28: Region wise RVs as on March 31, 2026 (Number) City / Region Land & Plant & Securities or Total Building Machinery Financial Assets New Delhi 96 39 278 413 Rest of Northern Region 527 105 420 1052 Mumbai 126 55 345 526 Rest of Western Region 932 180 424 1536 Chennai 121 46 165 332 Rest of Southern Region 1225 141 562 1928 Kolkata 38 20 125 183 Rest of Eastern Region 69 14 55 138 Total 3134 600 2374 6108 The average age of RVs as on March 31, 2026, stood at 49 years across asset classes. It was 49 years for Land & Building, 52 years for Plant & Machinery and 50 years for Securities or Financial Assets (Table 29). Of the 6108 RVs as on March 31, 2026, 635 RVs (constituting about 10% of the total RVs) are females.

28 E.8 Examinations E.8.1 Limited Insolvency Examination The IBBI publishes the syllabus, format, etc. of the examination under regulation 3(3) of the IBBI (Insolvency Professionals) Regulations, 2016. It reviews the same continuously to keep it relevant with respect to dynamics of the market. It has successfully completed seven phases of the Limited Insolvency Examination. The eighth phase commenced on July 1, 2023, and concluded on September 30, 2025. The ninth phase begins on July 1, 2025. It is a computer based online examination available on daily basis from various locations across India. NSEIT Limited is the current test administrator. The details of the examination are given in Table 31. Table 31: Limited Insolvency Examination Phase Period Number of Attempts Successful (some candidates made Attempts more than one attempt) First Jan, 2017 – Jun, 2017 5329 1201 Second Jul, 2017 – Dec, 2017 6237 1112 Third Jan, 2018 – Oct, 2018 6344 1013 Fourth Nov, 2018 – Jun, 2019 3025 505 Fifth Jul, 2019 – Dec, 2020 5860 1016 Sixth Jan, 2021 – Feb, 2022 2741 474 Seventh Mar, 2022 – Jun, 2023 1677 198 Eighth Jul, 2023 - June, 2025 1479 243 Ninth July-Sept, 2025 155 24 Oct- Dec, 2025 174 23 Jan-Mar, 2026 177 29 Total 33198 5838 E.8.2 Valuation Examinations The IBBI, being the authority under the Valuation Rules commenced the Valuation Examinations for asset classes of: (a) Land and Building, (b) Plant and Machinery and (c) Securities or Financial Assets, on March 31, 2018. It reviews the examinations continuously to keep it relevant with the changing times. Presently, the fifth phase of valuation examinations is going on from May 1, 2024. It is a computer based online examination available from several locations across India. National Institute of Securities Markets is the current test administrator. The details of the Examinations are given in Table 32. Table 29: Age profile of RVs as on March 31, 2026 Age Group Land & Plant & Securities or Total (in years) Building Machinery Financial Assets < 30 93 1 65 159

30 < 40 809 76 831 1716 40 < 50 533 122 792 1447 50 < 60 976 171 396 1543 60 < 70 633 152 252 1037 70 < 80 79 71 36 186 80 11 7 2 20 Total 3134 600 2374 6108 E.7 Complaints and Grievances The IBBI (Grievance and Complaint Handing Procedure) Regulations, 2017 enable a stakeholder to file a grievance or a complaint against a service provider. Besides this, grievance and complaints are received from the Centralised Public Grievance Redress and Monitoring System (CPGRAMS), Prime Minister’s Office (PMO), MCA, and other authorities. The receipt and disposal of grievances and complaints till March 31, 2026 is presented in Table 30. Table 30: Receipt and Disposal of Grievances and Complaints till March 31, 2026 (Number) Year / Complaints and Grievances Received Total Quarter Under the Through Through Recei- Dispo-Under Regulations CPGRAM/PMO/ Other ved sed Exami- MCA/Other Modes nation Authorities Rece- Dispo- Rece- Dispo- Rece- Dispo- ived sed ived sed ived sed 2017 – 18 18 0 6 0 22 2 46 2 44 2018 – 19 111 51 333 290 713 380 1157 721 480 2019 – 20 153 177 239 227 1268 989 1660 1393 747 2020 – 21 268 260 358 378 990 1364 1616 2002 361 2021 – 22 276 279 574 570 611 784 1461 1633 189 2022 – 23 235 211 399 386 238 272 872 869 192 2023 – 24 209 193 435 452 311 271 955 916 231 2024 – 25 267 239 320 342 316 314 903 895 239 Apr-Jun, 2025 66 85 115 96 57 101 238 282 195 Jul-Sep, 2025 79 99 120 127 62 62 261 288 168 Oct-Dec, 2025 53 70 107 119 96 83 256 272 152 Jan-Mar, 2026 67 75 166 165 81 91 314 331 135 Total 1802 1739 3172 3152 4765 4713 9739 9604 135

29 Table 32: Valuation Examinations Phase Period Number of Attempts Number of Successful (some candidates made Attempts in Asset Class more than one attempt) in Asset Class Land & Plant & Securities Land & Plant & Securities Building Machi- or Financial Building Machi- or Financial nery Assets nery Assets First Mar, 2018 – 9469 1665 4496 1748 324 707 Mar, 2019 Second Apr, 2019 – 3780 757 4795 380 95 656 May, 2020 Third Jun, 2020 – 8370 2015 8377 620 139 781 Jun, 2022 Fourth Jul, 2022 - 4042 764 2459 392 72 262 Apr, 2024 Fifth May, 2024 - 235 32 145 31 6 17 Jun, 2024 Jul,2024- 391 51 181 54 10 21 Sep, 2024 Oct 2024- 372 40 164 55 8 21 Dec, 2024 Jan-Mar, 2025 338 52 245 47 5 19 Apr–Jun, 2025 333 42 293 36 7 32 Jul-Sep, 2025 251 30 225 35 3 20 Oct-Dec, 2025 376 34 214 52 4 16 Jan-Mar, 2026 355 48 291 53 3 30 Total 28457 5553 21969 3515 677 2590 E.9 Disciplinary Orders During the quarter, the Disciplinary Committee/Authority of the IBBI disposed of 13 show cause notices issued to the IPs, 10 show cause notices issued to RVs, 1 to RVO and 2 appeals preferred by RVs for contravention of the provisions of law by passing suitable orders. F. Orders F.1 Supreme Court Satinder Singh Bhasin Vs. Col. Gautam Mullick & Ors. [Civil Appeals No. 13628 of 2025 with ors.] Allottees of office spaces in a real estate project sought initiation of CIRP against M/s Bhasin Infotech and Infrastructure Pvt. Ltd (Developer) and M/s Grand Venezia Commercial Towers Pvt. Limited (marketing entity) (CDs), alleging failure to deliver possession of the allotted units despite payment of consideration. AA admitted the petition and initiated a consolidated CIRP against both CDs. The erstwhile directors challenged the admission order before the NCLAT. During the pendency of the appeals, the NCLAT noted an RP’s status report indicating that significant portions of the building remained incomplete, with several floors existing only as bare structures without basic infrastructure. Consequently, the NCLAT dismissed the appeals and affirmed the initiation of CIRP. Subsequently, the erstwhile directors approached the SC. The issue before the SC was whether the insolvency proceedings could be jointly initiated against two corporate entities involved in the same real estate project. The SC held that both companies were intrinsically connected to the project, sharing common directors and undertaking integrated functions relating to development and sale of units. Accordingly, initiation of joint insolvency proceedings against them was justified to effectively address the claims of the allottees and maximise value. Elegna Co-Op. Housing and Commercial Society Limited Vs. Edelweiss Asset Reconstruction Company Limited & Anr. [Civil Appeal No. 10261 of 2025] Takshashila Heights India Pvt. Limited, (CD) undertook development of a residential-cum-commercial project and availed two term loan facilities aggregating Rs. 70 crore from ECL Finance Limited in July 2018. Subsequently, the debt was assigned to Edelweiss Asset Reconstruction Company Limited (FC), which issued recall notices and initiated recovery proceedings under the SARFAESI Act. Later, the parties entered into a One Time Settlement (OTS) under which the CD agreed to repay Rs. 55 crore in instalments. The CD paid the first instalment but defaulted thereafter, leading FC to revoke the OTS arrangement and initiate CIRP under section 7 of the Code. The AA, while rejecting the application, observed that since the project was substantially completed, initiation of CIRP could adversely affect homebuyers and other stakeholders. In appeal filed by the assignee, the NCLAT set aside the AA order and directed admission of the CIRP, holding that once debt and default are established, the application must be admitted. Further, NCLAT rejected an intervention application filed by the resident’s welfare association (RWA) of the CD since it did not fall within the category of financial creditor. Aggrieved, the CD and the RWA filed appeals before the SC. The issues before the Hon’ble SC were as follows: (i) Whether the AA was justified in rejecting a section 7 application despite the existence of debt and default, on the ground that the project was viable and CIRP would adversely affect homebuyers. (ii) Whether a third party such as a RWA has locus standi to intervene in proceedings relating to initiation of CIRP. SC observed that considerations such as project viability, business status as going concern, stage of completion, or perceived prejudice to homebuyers are extraneous and irrelevant at the admission stage. Accordingly, the SC held that once the AA is satisfied that a financial debt exists and a default has occurred, it must admit the application. On the second issue, the SC held that while individual allottees are “financial creditors” under the Explanation to section 5(8)(f), this status does not automatically extend to a RWAs unless it is a creditor in its own right or a statutorily recognized authorized representative. Additionally, SC, while disposing of the civil appeal, directed that (i) the Information Memorandum must disclose comprehensive details of all allottees; (ii) the CoC must record specific written reasons if they find it not viable to approve handover of possession under regulation 4E of CIRP Regulations, 2016; and (iii) any recommendation for liquidation must be accompanied by a reasoned justification by the CoC.

30 Gloster Limited Vs. Gloster Cables Limited and Ors. [Civil Appeal No. 2996 of 2024] Gloster Industries Limited (CD) entered into various technical collaboration and licensing agreements with Gloster Cables Limited (GCL) during the year 1995 and 2008. Further, through a Supplemental Trademark Agreement, the CD assigned the trademark “Gloster” to GCL for Rs. 10 lakh. Later, the CD was admitted into CIRP, pursuant to an application filed by a former employee under section 9 of the Code. The resolution plan submitted by Gloster Limited (SRA) was approved by the CoC. During the pendency of the approval by the AA, GCL had filed an application under section 60(5) of the Code before the AA seeking directions that the trademark “Gloster” should not be treated as an asset of the CD and should be excluded from the resolution plan, claiming ownership of the mark based upon the trademark agreement. However, the AA held that the trademark “Gloster” was an asset of the CD, with the consequence that the SRA would be entitled to it upon implementation of the resolution plan. Aggrieved by the finding, GCL preferred an appeal before the NCLAT. In appeal, the NCLAT set aside the AA’s finding and held that the AA could not adjudicate upon the dispute over title of the trademark under section 60(5) of the Code. In appeal, the SC held that while dealing with approval of the resolution plan, the AA could not have proceeded to determine the title to the trademark “Gloster” or declare it as an asset of the CD. Such determination involved questions beyond the limited inquiry permissible under the Code. State Bank of India Vs. Union of India and Ors. [Civil Appeal No. 1810 of 2021 with ors.] Telecom companies of the Aircel Group, namely Aircel Limited, Aircel Cellular Limited and Dishnet Wireless Limited (CD), were granted telecom licences by the Department of Telecommunications (DoT) under the service licence agreements. SBI (FC) extended credit facilities to the CD on the strength of a tripartite agreement between the FC, Service Provider and the DoT. Owing to financial distress of the CD, the FC initiated CIRP under the Code, and a resolution plan submitted by UV Asset Reconstruction Company (SRA) was approved by the CoC. Aggrieved by the approval of the resolution plan, the DoT challenged the order before the NCLAT contending that spectrum is a natural resource owned by the State and cannot be dealt with as an asset of the CD under the Code. The NCLAT held that spectrum constitutes an intangible asset of the licensee, which is capable of being dealt with in insolvency proceedings. Moreover, the NCLAT held that the spectrum cannot be utilized without payment of requisite dues, which cannot be wiped off by triggering CIRP under the Code. Further, the dues payable to DoT under the licence agreements fall within the ambit of operational debt under the Code. Aggrieved by the findings of the NCLAT, multiple appeals were filed before the SC by FCs as well as the DoT. The issues before the SC were (i) whether spectrum, allocated to telecom service providers under the licence agreements, can be treated as an asset of the CD under the Code, and (ii) whether insolvency proceedings can affect the ownership, control or transfer of spectrum which is a natural resource held by the State. SC held that the ownership and control of telecom spectrum cannot be determined by the Code, due to the following reasons: - (i) Interpreting section 4 of the Indian Telegraph Act, 1885, the Court held that the Central Government has exclusive privilege to establish, maintain and work telegraphs and may grant licences on such terms and consideration as it thinks fit. Thus, a licence granted under section 4 is contractual in form but emanates from sovereign statutory power and remains subject to constitutional limitations. (ii) Grant of a telecom licence does not transfer ownership of spectrum. It confers only a limited, conditional and revocable right to use spectrum for a defined purpose and duration. The licence remains subject to strict compliance with statutory requirements, licence conditions and public interest considerations. Thus, the insolvency framework cannot be used to rewrite the statutory regime governing natural resources. (iii) On the argument that spectrum is treated as an intangible asset in company balance sheets, the Court noted that accounting recognition under Indian Accounting Standards is based on control over economic benefits and reliable measurement of cost. This recognition, the Court held, does not determine legal ownership of Spectrum. (iv) While rejecting the contention that spectrum usage rights can be treated as a security interest in favour of lenders in view of the Tripartite Agreement, the SC noted that while the agreement facilitates conditional transfer or assignment in the event of default, such transfer remains subject to the licensor’s approval and regulatory control. It emphasised that the licence remains a regulated privilege rather than freely alienable asset. (v) The Court noted that the grant of a telecom licence does not transfer ownership of spectrum. It confers only a limited, conditional and revocable right to use spectrum for a defined purpose and duration. The licence remains subject to strict compliance with statutory requirements, licence conditions and public interest considerations. The Court held that the insolvency framework cannot be used to rewrite the statutory regime governing natural resources. Accordingly, the SC concluded that the resolution professional cannot assume control or custody over spectrum under section 18 of the IBC, as spectrum is neither owned by the corporate debtor nor transferable as property. S. Rajendran Vs. Deputy Commissioner of Income Tax (Benami Prohibition) and Ors. [Civil Appeal No. 7140 of 2022 with ors.] A benami transaction came to the light on investigation by the authorities under the Prohibition of Benami Property Transactions Act, 1988, “Benami Act”; which revealed that the promoters of the CD- Padmaadevi Sugars Limited had transferred their 100% shareholding to the beneficial owner, through an intermediary for a consideration of approximately Rs. 450 Crores. Meanwhile, insolvency proceedings were initiated against CD by an order dated 15.102018 of the AA, subsequently resulting in liquidation of CD. In furtherance to the process under the Benami Act, SCN dated 01.11.2019 was issued by the authorities under Benami Act wherein characterizing the CD, as the benamidar and the transaction as a “benami transaction” followed by a provisional attachment order, attaching the immovable properties of the CD. Such attachment was challenged by the liquidator before the AA based on applicability of the moratorium. AA rejected such application stating that the remedy lies exclusively before the competent forum constituted under the Benami Act. An appeal was preferred before the NCLAT, followed by another appeal before

31 SC challenging order of NCLAT wherein it refused to interfere with appeal challenging the provisional attachment orders. Similar, line of facts follows in the matter of the Senthil Papers and Board Private Limited against which CIRP commenced on 14.11.2017 and order of liquidation was passed on 14.02.2019. Issues for consideration before SC in both the appeals were whether the legality and validity of an order of attachment under Benami Act can be challenged before the statutory tribunals under IBC and whether the two enactments can be harmoniously construed and if not, which statutory regime must prevail in the limited sphere of conflict. SC observed that (i) the residuary jurisdiction conferred upon the AA under section 60(5) of the Code is not all pervasive. While it empowers AA to decide questions of law or fact “arising out of or in relation to” the insolvency resolution, this jurisdiction does not extend to reviewing administrative or quasi-judicial orders passed under independent public law statutes. (ii) IBC does not provide an indirect route to challenge sovereign acts validly undertaken under a penal statute. (iii) moratorium is intended to protect the CD from “creditor actions” aimed at debt recovery, not to shield “tainted assets” from sovereign actions against crime. (iv) the provision of section 32A of IBC does not validate defective title nor retrospectively convert benami property into assets of the CD. (v) where the subject matter of the dispute pertains to the exercise of sovereign statutory power, particularly in relation to determination of legality of title, attachment or confiscation and vesting thereof, the adjudicatory fora under the IBC must necessarily yield to the specialised mechanism created by such statute. The attachment and eventual confiscation of property thereunder operate in rem and culminate in vesting of the property in the Central Government free from encumbrances. Such consequences are penal and deterrent, rooted in statutory illegality, and are enforced through a distinct adjudicatory hierarchy whose jurisdiction is expressly insulated from ordinary civil fora. ICICI Bank Limited Vs. Era Infrastructure (India) Limited [Civil Appeal No. 6094 of 2019 with ors.] ICICI Bank extended credit facilities to group/related companies of Era Infra Engineering Private Limited (guarantor) i.e. ERA Infrastructure (India) Limited (CD), Hyderabad Ring Road Project Private Limited, Apex Buildsys Limited, Dehradun Highway Projects Limited and Gwalior Bypass Project Limited. On default incurred by the CD, ICICI bank initiated the IRP against the guarantor, and its claim was admitted by the RP. Meanwhile, the bank initiated separate CIRP against the CD under section 7 of the Code, which was dismissed by the AA on the ground that the same debt had already formed the basis of an admitted claim in the IRP of the guarantor. In appeal, the NCLAT upheld the order of the AA, in lieu of the ratio of SC judgment in Vishnu Kumar Agarwal v. Piramal Enterprises Limited. In appeal before the SC, the issues were as follows (i) Whether simultaneous proceedings for CIRP against the principal debtor and as its corporate guarantor, or vice versa, are maintainable? (ii) Whether the doctrine of election applies upon the creditor, to elect between proceedings against the principal debtor and the guarantor? (iii) Whether simultaneous proceedings may lead to unjust enrichment or double recovery by the creditor? (iv) Whether guidelines or modalities should be laid down by the SC to regulate simultaneous proceedings against group/related entities? The SC held that simultaneous or separate CIRP proceedings against both the principal debtor and the corporate guarantor are maintainable under the Code, as there is no statutory bar or requirement for election of remedies. Moreover, the SC held that the doctrine of election does not apply under the Code, and sufficient safeguards exist under regulation 12A and regulation 14 of the CIRP Regulations, 2016 which require creditors and resolution professionals to update claims as and when satisfied from any source. The SC declined to lay down further guidelines, leaving such matters to the wisdom of the legislature and IBBI. Thus, the impugned orders barring simultaneous proceedings were set aside, and appeals seeking to prohibit such proceedings were dismissed. Torrent Power Limited Vs. Ashish Arjunkumar Rathi & ors. [Civil Appeal No. 11746-11747/2024] SKS Power Generation (Chhattisgarh) Limited (CD) underwent CIRP initiated by Bank of Baroda (FC). SEML (SRA) and six other applicants submitted their Resolution Plans. The CoC approved SEML’s resolution plan with 100% vote after due negotiations. AA initially remitted the plan for reconsideration by CoC and thereafter approved SEML’s plan. In the appeal filed by the PRAs, the NCLAT rejected the appeal and upheld the resolution plan of the SRA. On further appeal before the SC, the PRA contended that the SRA allegedly enhanced his plan by increasing the amount of bank guarantee and converted deferred payment of Rs.240 crores to upfront payment for the implementation of the resolution plan. The issues before the SC were as follows: - (i) whether the clarifications furnished by SRA pursuant to queries raised by the RP in relation to the treatment and replacement of BGs and the option of upfront payment, resulted in any enhancement or modification of the resolution plan? (ii) whether the resolution plan, having been approved by the AA and implemented as on date, requires interference by SC? The SC while disposing of the appeal observed that there is a growing trend of unsuccessful resolution applicants challenging almost every commercial decision of the CoC under the guise of procedural impropriety and turning the insolvency process into a protracted adversarial contest. Further, the SC noted that the CoC identified ambiguities and directed the RP to seek clarifications from all resolution applicants. Moreover, the RP did not take any independent or unilateral decision but communicated the CoC’s queries and placed all responses before it. Accordingly, the SC concluded that such conduct is not material irregularity under Section 61(3) of the Code. Since the resolution plan has already been implemented, the SC affirmed the approval of the resolution plan and dismissed the impugned appeal. UJAAS Energy Limited Vs. West Bengal Power Development Corporation Limited [SLP (Civil) No. 29651 Of 2024] West Bengal Power Development Corporation Ltd (WBPDCL) floated a tender for installation of grid-connected rooftop solar power plants, and Ujaas Energy Limited (CD) was awarded the work vide Letter of Award dated 12.05.2017. On 17.09.2020, the CD was admitted into CIRP under section 9 of the Code. Due to certain disputes relating to performance of the contract, the CD invoked the arbitration clause vide a notice dated 31st December 2021. A statement of claim was filed by CD, while WBPDCL filed a

32 statement of defence/ counterclaim against the CD before the Arbitral Tribunal. However, the claim raised in the counterclaim was never pursued by WBPDCL during the CIRP of the CD. The CD approached the Arbitral Tribunal under section 16 of the Arbitration & Conciliation Act, 1996 (A & C), claiming that the jurisdiction of the tribunal is ousted by virtue of moratorium under section 14 of the Code. Meanwhile, the AA had approved the resolution plan for the CD vide order dated 13.10.2023. Thereafter, CD filed an application under section 31(6) of the A&C Act seeking dismissal of the counterclaim, on the ground that claims not part of the resolution plan stood extinguished. The tribunal dismissed the counterclaim of WBPDCL vide an interim arbitral award. WBPDCL appealed before a single judge-bench of the Calcutta High Court, which dismissed the appeal. However, on appeal, the division bench of the HC allowed the appeal and directed the tribunal to resume the arbitral proceedings. Aggrieved with the order, the CD approached the SC. The issue before the SC was whether WBPDCL shall be allowed to raise the issue of counterclaim before the tribunal, when the same has not been raised during the CIRP of the CD? The SC noted that payments or settlements for any claims, including counterclaims in pending arbitration proceedings, stood extinguished upon its approval. However, the SC held that resolution plan does not bar a plea of set-off as a defence in pending arbitral proceedings, solely to the extent necessary to defend against the CD’s claim, without entitlement to any affirmative relief or recovery. F.2 High Court Roseland Buildtech Pvt. Limited Vs. Vihaan 43 Reality Pvt. Limited and ors. [C.S. (COMM.) 812/2025] FC extended a credit facility of Rs. 80 crore to Roseland Buildtech Pvt. Limited (CD) under a loan agreement. Subsequently, the FC assigned the said loan in favour of another entity under a Business Transfer Agreement (BTA). After the assignment, the assignee claimed default in repayment of the loan and filed a petition under section 7 of the Code. The CD disputed the existence of any outstanding debt and contended that the loan liability had already been discharged through various payments. It further alleged that the BTA and related documents relied upon by the FC were fraudulent and forged. On this basis, the CD instituted a civil suit before the Delhi High Court seeking declarations that the loan stood fully discharged, the BTA was unenforceable, and the documents relied upon by the creditor were not binding upon it. The FC filed an application under Order VII Rule 11 of the Code of Civil Procedure, 1908, seeking rejection of the plaint on the ground that the issues raised in the suit related to the existence of debt and validity of documents, which fall within the exclusive jurisdiction of the AA under the IBC. The Delhi High Court observed that the issues were as follows: (i) whether the FC held a valid debt against the CD and (ii) whether the BTA relied upon to prove such debt was genuine. Accordingly, the HC held that the AA has powers to adjudicate upon issues concerning fraud, forgery, collusion and the validity of the documents based on which debt is sought to be proven by a given financial creditor under sections 65, 75, 60(5)(c) of IBC read with NCLT Rules, 2016. Thus, the HC concluded that the AA is empowered to delve into seriously disputed questions of fact, and examine, record, and evaluate evidence in the form and manner as it considers necessary. F.3 National Company Law Appellate Tribunal Pragiti Construction Vs. CoC of Rancom Healthcare Pvt. Limited & ors. [CA(AT) (Ins.) No. 2330 & 2331 of 2024] The CIRP of Rancom Healthcare Pvt. Limited (CD) commenced on an application filed under section 9 of the Code, by M/s Mahavir Medicare (OC). In the invitation of EoI process, the RP declared M/s Pragiti Construction (PRA) and OC were declared eligible PRA. The PRA, though eligible, could not submit its resolution plan within the original or extended timelines citing non-availability of requisite information from the RP. The PRA sought permission to submit its resolution plan beyond the stipulated deadline; however, the CoC rejected the request. Aggrieved thereby rejection, the PRA approached the AA, which directed the RP to convene a meeting of the CoC for consideration and decision on the resolution plan submitted by the PRA. The CoC, consisting solely of OC with 100% voting rights, rejected the plan citing expiry of the CIRP period. The PRA approached the AA on the ground that no cogent reasons were provided by the CoC while rejecting the plan. However, the AA rejected the contentions of the PRA and approved the resolution plan of the OC. In appeal, the issues before the NCLAT were as follows (i) whether a resolution applicant who is also an OC of the CD and sole member of the CoC, can approve its own resolution plan? (ii) whether such a CoC, consisting of only one member who is also a resolution applicant and directly interested in the outcome, can fairly, objectively, and independently assess the feasibility and viability of competing resolution plans, particularly when comparative evaluation and discretion are required? The NCLAT held that a resolution applicant who is not a FC cannot vote on and approve its own resolution plan, declaring such approval void ab initio as it violates section 30(5) of the IBC. The NCLAT found that there were no proper comparative evaluations of the two plans and no structured assessment of their feasibility and viability. Moreover, the PRA was not invited to the meeting where its plan was discussed and rejected. Thus, the NCLAT while allowing the appeal and setting aside the approved resolution plan held that where only member of the CoC was also the competing resolution applicant and beneficiary, such a process could not be said to be fair, transparent, or impartial. IDFC First Bank Limited Vs. Seikh Abdul Salam, Resolution Professional of Jai Gokul Towers Pvt. Ltd and Ors. [CA (AT) (Ins.) No. 848 of 2024 & I.A. No. 7183 of 2024] IDFC First Bank Limited (FC) sanctioned a term loan of Rs. 25 crores to a company, with Jai Gokul Towers Pvt. Limited (CD) as one of the guarantors. An immovable property was mortgaged as security for the loan, wherein the CD held 1/6th share. Later, the FC obtained a consent decree from the Bombay High Court for recovery of dues, and the execution proceedings were transferred to DRT Mumbai for issuing a Recovery Certificate to the FC, pursuant to which a sale proclamation was issued. In the auction conducted by the Recovery Officer, Quest Queen Vista LLP was declared the successful auction purchaser. However, the issuance of the sale certificate was kept in abeyance due to an interim stay order of the Calcutta High Court. Meanwhile, the CD was admitted into CIRP by the AA vide order dated 01.01.2024, and moratorium under Section 14 of the Code was imposed. By virtue of the proceedings

33 under the Code, the Calcutta High Court recalled its interim order. Accordingly, the Recovery Officer issued the sale certificate and handed over the possession to the auction purchaser. However, the RP filed an application before AA seeking declaration that the sale was void since the sale certificate was issued during the moratorium, which was approved by the AA and the auction purchaser was directed to restore the possession of the property to the RP. Aggrieved with the order, the FC and auction purchaser filed an appeal before the NCLAT. The issues before the NCLAT were as follows: (i) Whether the confirmation of sale of the CD’s property by the Recovery Officer, prior to commencement of CIRP, which resulted in the sale becoming absolute and title vesting in the auction purchaser, is valid, notwithstanding the subsequent issuance of the sale certificate after the commencement of CIRP. (ii) Whether the AA was correct in declaring the sale as void and directing restoration of possession to the RP on the ground that the sale certificate was issued after commencement of CIRP? The NCLAT observed that the AA failed to consider the effect of confirmation of sale, which was prior to CIRP commencement, and the effect of the subsequent issue of sale certificate. Thus, the NCLAT concluded that where confirmation of sale of the CD’s property by the Recovery Officer under the Second Schedule of the Income Tax Act, 1961 was made prior to the commencement of the CIRP, the sale became absolute on the date of confirmation, and the subsequent issuance of the sale certificate is merely ministerial and does not affect the vesting of title. Minita D Raja Vs. The Cosmos Co-Op Bank Limited [I.A. No. 6569 of 2023 in CA (AT) (Ins) No. 1799 of 2024] The CIRP of the CD (Crystal Clear Veg Oil Refinery Pvt. Ltd) was commenced in April 2018, and Minita D Raja was appointed as the RP. Only one resolution plan was received, which was rejected by the CoC. Later, the CoC resolved to withdraw the CIRP under section 12A of the Code. An application under section 12A was filed in April 2019 but was initially rejected by the AA in January 2021. In appeal, the NCLAT remanded the matter back to AA for reconsideration of the withdrawal application on merits. The withdrawal application was finally allowed by the AA in January 2024. The CoC had initially fixed the RP’s fee at Rs. 2,50,000/- per month, which was subsequently reduced by the AA to Rs. 50,000/

• per month for July 2020 to March 2023. The RP sought payment of fees for April 2023 to January 2024 at the rate fixed by the AA, but the CoC contended that the RP did not perform any work during that period. The AA further reduced the RP’s fee to Rs. 10,000/- per month for the disputed period. Aggrieved with the order, the RP appealed under section 61 of the Code against the impugned order. The issues before the NCLAT were as follows: (i) Whether, after filing of an application under section 12A of the Code r/w regulation 30A of the CIRP Regulations, the RP was entitled to be compensated for performing her duties as a RP till the same was allowed by the AA. (ii) Whether the AA could, on its own, fix the fee of the RP without any recommendations of the CoC? The NCLAT held that RP is entitled to fees up to the date of approval of withdrawal of the CIRP, by virtue of regulation 30A(7) of the CIRP Regulations, 2016, which enshrines that payment of expenses are payable up to date of approval order being passed by the AA, which includes expenses incurred on or by the RP. Moreover, the NCLAT held that the AA is empowered to fix the fees of the RP only to limited extent if the applicant (for initiation of CIRP) does not propose the amount for such remuneration. In view of regulation 34 of the CIRP Regulations, 2016, the CoC has exclusive jurisdiction to fix the fees, and in absence of its recommendation, the AA is not correct in fixing the fees of the RP. Thus, the NCLAT concluded that the RP is duty bound to continue looking after the affairs of the CD, after filing withdrawal application, till it is handed over to the management of the CD. BSE Limited Vs. Avil Menezes & Ors. [CA (AT) (Ins) No. 1862 of 2024 & 1786 of 2025] The demat accounts of Future Corporate Resources Pvt. Limited and Liz Traders and Agents Pvt. Limited (CDs) were frozen by Bombay Stock Exchange (BSE) due to non-payment of annual listing fees (ALF) as required under the listing agreement and relevant circular issued by the BSE. For Future Corporate Resources Pvt. Limited, CIRP was initiated on 24.09.2024, and the IRP requested de-freezing of the demat account, which was refused by BSE unless ALF dues were paid. For Liz Traders and Agents Pvt. Limited, CIRP was initiated on 25.02.2022, which was directed into liquidation. The liquidator discovered that the demat account was frozen and sought its de-freezing to sell shares and distribute proceeds. However, the liquidator was met with refusal by the BSE and NSE, on the grounds of non-compliance with relevant provisions of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. Aggrieved with the refusal, the CDs approached the AA, which directed de-freeze of the demat accounts. In appeal, the issues before the NCLAT were as follows: (i) Whether the AA has jurisdiction under section 60(5) of the Code to direct de-freezing of demat accounts of CDs frozen by stock exchanges for non-payment of annual listing fees, where such freezing was done prior to initiation of CIRP/liquidation. (ii) Whether section 238 of the Code can override the framework governing stock exchanges, to the extent of de-freezing demat accounts for the benefit of the insolvency resolution or liquidation process. (iii) Whether the moratorium under section 14 of the Code applies to actions taken by stock exchanges for failure in complying with their rules/regulations. (iv) Whether the crystallization of ALF and the absence of pending proceedings under the securities law bring the matter within the exclusive domain of the AA? The NCLAT held that where the ALF required to be paid by CD has been finalised/crystallized, and no further proceedings are pending before any fora under the securities law, and only the recovery of the fee is left, the matter will fall squarely within the parameters the Code. Moreover, the NCLAT held that the AA, by virtue of section 60(5) and section 238 of the IBC, would have jurisdiction to adjudicate upon such issues in accordance with the Code. F.4 National Company Law Tribunal Bhuvan Madan, RP of Jaiprakash Associates Limited Vs. CoC, Jaiprakash Associates Limited [IA (PLAN) NO.11/2025 in CP (IB) NO.330/ALD/2018] The CIRP of JAL was initiated, vide order dated 03.06.2024, by the AA. The resolution plan submitted by Adani Enterprises Limited was approved by the CoC in its 23rd meeting with a voting share of 93.81%. The approved resolution plan provides for implementation through Adani group entities or special purpose

34 vehicles. It envisages a total plan value of approximately Rs. 15343 crores, with a resolution amount of about Rs. 14543 crores. The core issue initiated after the issuance of the Request for Resolution Plan (RFRP) on 04.04.2025 and adoption of a challenge process on 28.08.2025 to enhance competitive bidding among resolution applicants. During the challenge process, Vedanta Limited emerged as the highest bidder (H1) on 05.09.2025 with a net present value (NPV) of Rs. 12,505.85 crore and subsequently submitted its final resolution plan on 14.10.2025. However, after the conclusion of the process, Vedanta submitted an addendum on 08.11.2025 seeking to enhance its upfront payment and equity infusion without altering the NPV. The RP placed the addendum before the CoC, which, in its commercial wisdom, rejected the same on the ground that it violated the terms of the RFRP and the Process Note, which expressly prohibited any modification to financial proposals after closure of the challenge process. For evaluating the resolution plans, the CoC applied an evaluation matrix comprising quantitative and qualitative parameters. On aggregate scoring, Adani achieved the highest score of 89.76, whereas Vedanta scored 75.60 out of 100. Although Vedanta’s plan reflected a higher NPV and gross value spread over a longer period of five years, Adani’s plan was preferred due to its significantly higher upfront cash payment and a shorter payout timeline of two years, thereby ensuring quicker value realization. The CoC placed balanced emphasis on value maximization and timely realization, as the core objectives to achieve under the Code. Vedanta Limited (Unsuccessful Resolution Applicant) challenged the decision by filing an interim application before the AA, contending that its plan offered superior value and that the evaluation process was arbitrary, particularly with respect to subjective qualitative parameters and undue weightage to upfront payment. It was further argued that the rejection of the addendum was unjustified as it merely restructured the payment terms to the benefit of creditors. However, the AA, vide its order dated 18.03.2026, upheld the actions of the CoC. While holding that the application was maintainable, the AA ruled that the rejection of the addendum was valid as it contravened the provisions of the RFRP, Process Note, and regulation 39(1A) of the CIRP Regulations. It further held that the evaluation matrix and the methodology adopted by the CoC were within the framework of the law and that the commercial wisdom of the CoC in approving the Adani plan could not be interfered with, except on limited grounds of statutory non- compliance. AA held that judicial review in such matters is confined to ensuring compliance with section 30(2) of the Code and does not extend to re-evaluating the commercial decisions of the CoC. It was observed that the CoC had acted within its domain in prioritizing a plan that ensured faster realization and higher upfront payment, thereby maintaining a balance between value maximization and value realization. Thus, the AA upheld the resolution plan submitted by Adani Enterprises Limited. G. Building Ecosystem G.1 IP Workshops IBBI has been organising workshops for registered IPs with the aim to deliver specialised and deep level learning through a classroom, non-residential mode. It organised several Workshops for the IPs during the quarter through online mode. The details of the workshops conducted till March 31, 2026, is given in Table 33. Table 33: Capacity Building Programmes for IPs till March 31, 2026 Year / Period Workshops WebinarsRoundtables Trainings Total 2016 - 17 1

8

9 2017 - 18 6

44

50 2018 - 19 7

22

29 2019 - 20 15 1 22

38 2020 - 21 9 29 18 2 58 2021 - 22 14 21 12 3 50 2022 - 23 18 6 6 6 36 2023 – 24 29 17 5 1 52 2024 - 25 22 3 2 1 28 Apr-Jun, 2025 3

3 July-Sept, 2025 8 2 2

12 Oct-Dec, 2025

4 4 Jan-Mar, 2026 4

1

Total 136 79 141 18 369 G.2 Advocacy and Awareness The IBBI in association with various stakeholders, organised advocacy and awareness programmes as presented in Table 34. Table 34: Advocacy and Awareness Programmes, Jan-Mar, 2026 Sl. Date Particulars Topic In No. association with 1 10.01.2026 Seminar on ‘Valuation ‘Valuation RVO ESMA Responsibility for maintaining Responsibility for Economic Sustainability’ maintaining Economic Sustainability’ 2 19.01.2026 EPFO Training programme Handling IBC 2016 EPFO on “Handling IBC 2016 Related Cases in Related Cases in EPFO & EPFO & Legal Legal Management” Management 3 08.02.2026 5th CNLU–CARCIL National Insolvency and CNLU IBC Moot Court Competition, Bankruptcy Code, 2026 2016 4 11.02.2026 Session on Mergers and Mergers and Boston Acquisitions Acquisitions Consulting Group (BCG) 5 12.02.2026 Workshop on the Insolvency Insolvency and EPFO and Bankruptcy Code (IBC) Bankruptcy Code (IBC) 6 21.02.2026 34th Quarterly Conference Challenges in Enforcement of Zonal Officers of Insolvency and Directorate Directorate of Enforcement Bankruptcy Code in Guwahati (IBC) 7 27.02.2026- 2-day physical workshop Simplifying Valuation ICMAI RVO 28.02.2026 ‘Simplifying Valuation’

35 Session on Mergers & Acquisitions, New Delhi, February 11, 2026 Training Programme for IPs, January 23- 25, 2026 Interactive Session with IPs, New Delhi, March 11, 2026 G.3 Other Programmes Senior Officers of IBBI participated as guests and faculty in several programmes during the quarter, the details of which presented in Table 35. Table 35: Participation of Senior Officers in Programmes Sl. Date Organiser Subject Participation No. 1 13.02.2026 – MoHUA National Urban and Real Mr. Jithesh John, 14.02.2026 Estate Development Executive Conclave 2026 Director, IBBI 2 21.02.2026 Enforcement 34th Quarterly Conference Mr. Jithesh John, Directorate of Zonal Officers of Executive Directorate of Enforcement Director, IBBI in Guwahati

36 A&C Arbitration and Conciliation AA Adjudicating Authority AFA Authorisation for Assignment ALF Annual Listing Fees AMCC Annual Mine Closure Costs AR Authorised Representative BIFR Board for Industrial and Financial Reconstruction BSE Bombay Stock Exchange BTA Business Transfer Agreement CCDs Compulsorily Convertible Debentures CD Corporate Debtor CEO Chief Executive Officer CERC Central Electricity Regulatory Commission CIRP Corporate Insolvency Resolution Process CIRP Regulations IBBI (Insolvency Resolution Process for Corporate Persons) Regulations, 2016 CoC Committee of Creditors CPE Continuing Professional Education CPGRAMS Centralised Public Grievance Redress and Monitoring System DoT Department of Telecommunications DRP Debt Realignment Plan DRT Debt Recovery Tribunal EBITDA Earnings Before Interest, Taxes, Depreciation, and Amortization ED Executive Director EMD Earnest Money Deposit EoI Expression of Interest EOW Economics Offences Investigation Wing EPFO Employees’ Provident Fund Organisation FC/FCs Financial Creditor / Creditors FIR First Information Report FiSP/FiSPs Financial Service Provider/ Financial Service Providers GCL Gloster Cables Limited H1 Highest Bidder HC High Court IBA Indian Banks’ Association IBBI / Board Insolvency and Bankruptcy Board of India IBC / Code Insolvency and Bankruptcy Code, 2016 ICAI Institute of Chartered Accountants of India ICAI RVO ICAI Registered Valuers Organisation ICD Insolvency Commencement Date ICLS Indian Corporate Law Service ICMAI Institute of Cost and Management Accountants of India ICSI Institute of Company Secretaries of India ICSI IIP ICSI Institute of Insolvency Professionals IDBI Industrial Development Bank of India IIIP ICAI Indian Institute of Insolvency Professionals of ICAI IIM Indian Institute of Management IP/IPs Insolvency Professional/ Professionals IPA/IPAs Insolvency Professional Agency/ Agencies IPA ICAI Insolvency Professional Agency of Institute of Cost Accountants of India List of Abbreviations IPE/IPEs Insolvency Professional Entity/Entities IRP/IRPs Interim Resolution Professional/Professionals ITD Income Tax Department IU/IUs Information Utility/Utilities LCD Liquidation Commencement Date Liquidation IBBI (Liquidation Process) Regulations, 2016 Regulations LOA Letter of Award MCA Ministry of Corporate Affairs MD Managing Director MoHUA Ministry of Housing and Urban Affairs MSME Micro, Small and Medium Enterprise NCD non-convertible debenture NCLAT National Company Law Appellate Tribunal NCLT National Company Law Tribunal NeSL National e- Governance Services Limited NITI Aayog National Institution for Transforming India NIUA National Institute of Urban Affairs NPV Net Present Value OC/OCs Operational Creditor/ Creditors OTS One-Time Settlement Panel Guidelines Insolvency Professionals to act as Interim Resolution Professionals, Liquidators, Resolution Professionals and Bankruptcy Trustees (Recommendation) Guidelines, 2024 PG/PGs Personal Guarantor/Guarantors PGIP Post Graduate Insolvency Programme PIRP Personal Insolvency Resolution Process PMLA The Prevention of Money Laundering Act, 2002 PMO Prime Minister’s Office PPIRP Pre-Packaged Insolvency Resolution Process PRA Prospective Resolution Applicant RBI Reserve Bank of India RERA Real Estate Regulatory Authority RFRP Request for Resolution Plan RoD Record of Default RP/RPs Resolution Professional/Professionals RV/RVs Registered Valuer/Registered Valuers RVO/RVOs Registered Valuer Organisation/Registered Valuer Organisations RWA Resident Welfare Association SARFAESI Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest SC Supreme Court of India SCN Show Cause Notice SCRA Securities Contracts (Regulation) Act, 1956 SEBI Securities and Exchange Board of India Act, 1992 SRA Successful Resolution Applicant Valuation Rules The Companies (Registered Valuers and Valuation) Rules, 2017 WBPDCL West Bengal Power Development Corporation Limited WP Writ Petition WTM Whole Time Member