NCLT Ahmedabad Dismisses Plea To Revise Admitted Claims Post Approval Of Sintex BAPL Plan

The National Company Law Tribunal, Ahmedabad Bench, has reinforced the sanctity of approved resolution plans under the Insolvency and Bankruptcy Code, 2016, in a recent judgment. The bench, comprising Hon’ble Member (Judicial) Mr. Shammi Khan and Hon’ble Member (Technical) Mr. Sanjeev Sharma, dismissed an interlocutory application filed by Machino Polymers Limited, which sought to modify its admitted claim against Sintex-BAPL Ltd. after the resolution process had already reached completion.

The Genesis of the Dispute

Machino Polymers Limited, an operational creditor involved in supplying polypropylene compounds, had filed claims against Sintex-BAPL Ltd. during its Corporate Insolvency Resolution Process. While the initial claim was partially admitted by the Interim Resolution Professional, the operational creditor sought to have the full amount recognized. During the transition to the Resolution Professional, the applicant continued to pursue its claims via multiple interlocutory applications.

However, prior to the adjudication of these issues, the Committee of Creditors approved a resolution plan for the corporate debtor, which the Tribunal subsequently sanctioned on March 17, 2023. Payments were subsequently distributed to operational creditors on a proportionate basis as mandated by the approved plan.

Arguments from the Parties

Machino Polymers argued that a post-resolution reconciliation of accounts revealed a revised principal claim figure. The creditor contended that its application was merely intended to rectify the books of account of the corporate debtor and would not prejudice other stakeholders or reopen the resolution process. In contrast, the erstwhile Resolution Professional, Mr. Ashish Chhawchharia, argued that he had become functus officio —lacking further authority once the implementation of the plan was concluded. He maintained that the approved plan is binding on all parties under Section 31 of the IBC and that any attempt to modify claims post-approval undermines the "clean slate" principle central to the insolvency framework.

Judicial Analysis of Statutory Finality

Acknowledging the arguments, the Tribunal observed that the primary objective of Section 31 of the Insolvency and Bankruptcy Code is to provide absolute certainty to the resolution process. The bench distinguished between the statutory functions assigned during the CIRP and the legal status of the process after the resolution plan has been implemented. The court clarified that neither Rule 11 of the National Company Law Tribunal Rules nor the general duties of the resolution professional could be invoked to override the legislative mandate of finality attached to an approved plan.

Key Observations

• "Upon approval of the Resolution Plan , Respondent No.1 ceased to discharge the functions of Resolution Professional and the management of the Corporate Debtor vested in the Successful Resolution Applicant."
• "The object of the provision is to provide certainty and finality to the resolution process and to facilitate implementation of the approved Resolution Plan ."
• "The inherent powers under Rule 11 cannot be exercised contrary to the express provisions of the Code and the statutory finality attached to an approved Resolution Plan ."

The Court’s Decision

The Tribunal ultimately concluded that it lacked the jurisdiction to order the modification of claims once the resolution plan attained legal finality. Consequently, the application (IA/42(AHM)2026) was dismissed. This ruling serves as a vital reminder to creditors that the claim verification stage is the definitive window for resolving disputes, as the subsequent approval of a resolution plan operates as a binding "clean slate" that precludes further revisions or accounting adjustments.