DAMODARAM SANJIVAYYA NATIONAL LAW UNIVERSITY

SABBAVARAM, VISAKHAPATNAM, A.P., INDIA

PROJECT TITLE :

“ANALYSIS OF SECTION 12A UNDER INSOLVENCY AND BANKRUPTCY CODE ’’

NAME OF THE SUBJECT

INSOLVENCY LAW

NAME OF THE FACULTY

PROF. GANTA. SATYANARAYANA

NAME OF THE CANDIDATE: M. SWETCHCHA

ROLL NO : 2019LLB089
SEMESTER : XTH SEMESTER

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 ACKNOWLEDGEMENT

I would like to express my special thanks of gratitude to my teacher, Prof. Ganta.

SatyaNarayarna , who gave me the golden opportunity to do this wonderful project on the
topic “ANALYSIS OF SECTION 12A UNDER INSOLVENCY AND BANKRUPTCY
CODE.”, which helped me in doing a lot of research and I came to know about so many new
things and I am really thankful to my professor. I am doing this project not only for marks but
also to increase my knowledge. I have tried my best to collect information about the project in
various possible ways to depict the clear picture about the given project topic.

- M. Swetchcha

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 TABLE OF CONTENTS

1. COVER PAGE………………………………………………………..1

2. ACKNOWLEDGEMENT……………………………………………2

3. ABSTRACT…………………………………………………………..4

4. SYNOPSIS…………………………………………………………….5

5. INTRODUCTION……………………………………………………….6

6. WITHDRAWAL OF CASES AT PRE-ADMISSION STAGE……………….8

7. POSITION UNDER IBC REGARDING POST ADMISSION SETTLEMENT –

PRE-SECTION 12A…………………………………………10

8. CURRENT POSITION – SECTION 12A OF THE IBC READ WITH

REGULATION 30A IBBI IRPCP REGULATIONS, 2016………………………….12

9. RECENT CASES……………………………………………………………..14
10. CONCLUSION ……………………………………………………………..16

11. BIBLOGRAPHY………………………………………………………………17

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 ABSTRACT

TOPIC NAME: ANALYSIS OF SECTION 12A UNDER INSOLVENCY AND

BANKRUPTCY CODE.

INTRODUCTION:

The Insolvency and Bankruptcy Code (IBC), 2016 was introduced to provide an effective
mechanism for speedy resolution, reorganization and revival of an insolvent company. Since its
implementation, many changes have been made to address issues to make it more effective. One
such change was made in 2018 by adding section 12A through the Amendment Act to resolve
and withdraw a case under a Corporate Insolvency Resolution Professional (CIRP). Before the
introduction of section 12A, when a debtor was brought into a corporate insolvency proceeding
(CIRP), it followed a relatively rigid path. The main objective was either to resolve the
insolvency and restructure the debtor's debts or, if this is not possible, to start liquidation
proceedings. However, parties had limited flexibility to resolve or cancel insolvency proceedings
once they had begun. Lack of flexibility often led to situations where viable resolution plans
could not be implemented for various reasons, including disputes between creditors. , regulatory
barriers or simply a change in circumstances. This led to the unnecessary liquidation of
otherwise viable businesses, causing a loss of value to creditors and stakeholders.

These shortcomings were recognized and the IBC was amended in 2018 to include Section 12A,
which provides a mechanism for withdrawal of insolvency petitions with the approval of the
National Company Law Tribunal (NCLT). The purpose of this change was to promote amicable
resolution between creditors and debtors outside of the formal insolvency process, thereby
speeding up resolution and preserving the value of distressed assets.

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 SYNOPSIS

OBJECTIVE OF THE STUDY:

The objective of the study is

A comprehensive understanding of Section 12A under the IBC and its role in the insolvency
resolution framework in India.

SCOPE OF THE STUDY:

The study helps to know about the would provide a holistic understanding of Section 12A under
the Insolvency and Bankruptcy Code and its implications for various stakeholders.

REASERCH QUESTIONS:

An Analysis of Section 12A under the Insolvency and Bankruptcy Code: Evaluating its Efficacy
in Facilitating Corporate Insolvency Resolution in India?

LITERATURE REVIEW: The analysis of the selected topic is based on online and Offline
sources viz., articles, books, websites and case studies.

REASERCH METHODOLOGY:

The study is based on doctrinal method of research and it is descriptive and explanatory study.

SECONDRAY SOURCES:

The researcher has taken information from secondary sources like web resources from online
articles and journals from Manupatra, business standards, economic times.

TYPE OF REASERCH:

This research is descriptive, analytical and explanatory study.

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INTRODUCTION:

The purpose of the Insolvency and Bankruptcy Act 2016 is to merge and transform the
Insolvency Act into a single piece of legislation and to regulate, among other things, the
insolvency of a corporate debtor. According to IBC Section 7, 9 and 10, the applicant can submit
a request to the relevant legal authority to start the insolvency of the debtor of the company,
which the applicant can also cancel before or after fulfilling certain conditions. The IBC
Withdrawal Application Act and related rules and regulations, together with an explanation of its
recent amendments, and legal opinions on the same withdrawal application that existed before
and after the 2021 IBC Amendment, emphasize the need to change and examine IBC Sec. Ratio
between 12A and 29A.

The Insolvency and Bankruptcy Code, 2016 (IBC) is a comprehensive law that deals with the
insolvency of companies, LLLs, SMEs and even individuals, as well as private and corporate
guarantors and partnerships.1 Both the Ministry of Corporate Affairs (MCA) and the Insolvency
and Bankruptcy Board of India (IBBI) have framed several rules and regulations to implement
the IBC. Cases related to insolvency and liquidation of companies, LLPs and SMEs are dealt
with by NCLT (Adjudicatory Authority), while insolvency of individuals and companies is dealt
with by Debt Recovery Tribunal (DRT). NCLT appeal is reviewed by Honourable NCLAT and
from there to Supreme Court, similarly DRT appeal is reviewed by Hon'ble DRAT and from
there to Supreme Court. According to the IBC, creditors can be classified as operational
creditors, financial creditors or other creditors that do not fall under these two definitions.

Operational creditors are those creditors who have a legally enforceable operating debt against
the company's debtors, while financial creditors are creditors who have a legally enforceable
financial debt against the company's debtors. According to Section 9 of the IBC, operational
creditors can register for insolvency. requests against the debtors of the company to the
appropriate judicial authority who have not paid, but before presenting such a request, the
operating creditor must present a request for payment against the debtor of the company in

1
Act No. 31 OF 2016

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accordance with section 8 of the IBC, if this is not possible, only he can execute the petition in
section 9. The existence of negligence can be proved by the following documents.

. Copy of the corresponding invoice.

. He received proof that the dispute related to the operational debt was not reported.

. Copy of the information kept by the Information Service.

. Proof that the financial institutions did not receive payment to keep the debt account of the
company.

. Other evidence confirming that the debtor of the company has not made the payment.

Section 9, subsection 5 of the Law states that if the application is complete in every way and
after consulting the legal entity debtor, an oversight appears on the part of the institution
conducting the procedure, it must process the request within 14 days of the submission of the
application, or if the application is incomplete, it must accept the application. the operating
creditor must correct the statements within 7 days. The Corporate Insolvency Resolution Process
(CIRP) begins on the day the challenged authority accepts a section 9 petition. Similarly, a
financial creditor can file an insolvency petition under section 7 of the IBC against a corporate
debtor to whom a debt is owed. Unlike a Section 9 application, at the request of a financial
creditor they must appoint an Insolvency Resolution Professional (IRP) to look after the affairs
of the corporate debtor if the application is accepted. In addition, in an application according to
section 7, the debtor of the company does not need to be notified in advance, and negligence can
be proven through the negligence protocol or another document kept by the information service.

Another difference between operational and financial creditors is that two or more financial
creditors can make an application under section 7 together, but the same does not apply to an
operational creditor. Consequently, section 4 and 5 of section 7 provide that if the application is
complete in all respects and after consultation with the legal entity the debtor has proven
negligence to the legal authority, it must process the request within 14 days of the presentation of
the application or when the application is submitted is incomplete, the operating creditor must be
able to correct the applications within 7 days. Under Section 7(6) of the Act, the Company

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Insolvency Resolution Process (CIRP) begins on the day the Authority approves an application
under Section 7.

 WITHDRAWAL OF CASES AT PRE-ADMISSION STAGE

Before a court accepts an insolvency petition against a company debtor, the company debtor and,
as the case may be, an operational or financial creditor may settle matters at any time. The
parties can choose to settle out of court or, alternatively, they can ask a mediation agency to
mediate the matter .If the parties reach an agreement, they can make a settlement and then the
creditor can submit the case to mediation. . In 2016, an application under Rule 8 of the
Insolvency and Bankruptcy Rules (application to the issuing authority) requesting the withdrawal
of the application. However, it may be noted that the agreement between the parties must be
voluntary and the conciliation agency cannot compel the parties to an agreement as observed by
the Supreme Court in ES Krishnamurthy v. Bharath Hi Tech Builders Ltd. (2021) IBC law.
in 173 SC2, where it held that both the courts and the NCLAT are statutory courts and not
equitable courts and are bound by the provisions of the IBC, it was further held that they can
promote arbitration and have to decide the request for insolvency strictly IBC.

Also the Hon'ble Supreme Court in Swiss Ribbons Pvt. Ltd. vs. Union of India [2019] IBC
law.3 In 03 SC judicially recognized the exercise of inherent power under Rule 11 of the NCLT
Rules, 2016 to allow conciliation applications made before the creation of the COC, but also
cautioned that such applications must be decided by the negotiating authority on a case-by-case
basis, after consultation with all parties and taking into account all relevant factors.

2
(2021) ibc law. in 173 SC
3
[2019] ibclaw.in 03 SC

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Initially, a creditor (financial or operational) or the debtor himself files an application for
insolvency resolution of the corporate debtor with the NCLT. After receiving the application, the
NCLT will review it to determine whether it meets the requirements of the IBC. This is the pre-
acceptance. If the applicant (debtor or debtor) wants to withdraw his application, he can do so
under section 12A of the IBC. This section allows applications to be withdrawn prior to
acceptance under certain conditions. Cancellation under Section 12A may be subject to
conditions imposed by the NCLT. These terms may include the payment of costs or other
obligations incurred during the insolvency proceedings up to that time. Once the cancellation is
accepted by the NCLT, the insolvency resolution process initiated by the application ends.

The debtor retains control of its assets and operations, and creditors cannot take further action
under the IBC based on this application. It is important to note that the withdrawal of a debtor
before the approval stage does not prevent creditors from starting new proceedings under the
IBC if circumstances warrant in the future. Generally, section 12A withdrawals are in the pre-
acceptance phase gives creditors and debtors the flexibility to reconsider their decision to seek
insolvency resolution, especially if alternative measures are found to solve the debt problem or
circumstances change. There is no provision for withdrawal of an application to the NCLT under
the Insolvency and Bankruptcy Code, 2016 ("IBC"), except under Rule 8 (Application to NCLT)
of the Insolvency and Bankruptcy Rules, 2016, where the NCLT may permit. With drawl of the
application at the request of the applicant before the application is accepted. The report of the
Insolvency Law Commission also recommended that Rule 8 be amended to allow CIRP approval
to be revoked. Section 12A was later added by an amendment order of 6 June 2018, authorizing
the decision-making body to allow a CIRP applicant to withdraw an application by a 90% vote
and with the approval of the Contributor Committee "as may be prescribed."

Rule 8 (Application to Issuing Authority) of the Insolvency and Bankruptcy Code, 2016, Section
12A of the Insolvency and Bankruptcy Code, 2016 read with Rule 30A (Process of resolution of
insolvency of corporate persons) of the Insolvency and Bankruptcy Board of India, Application
2016. Financial creditor, operational creditor and corporate debtor himself will file a corporate
insolvency resolution proceeding (CIRP) with the NCLT under Section 7, 9 or 10 of the IBC and
it can be withdrawn under Sec. IBC.

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  POSITION UNDER IBC REGARDING POST ADMISSION SETTLEMENT –
PRE-SECTION 12A

Regarding post-admission matters, in the absence of statutory legislation, the Appellate Body
relied on the right under Rule 11 of the National Company Appellate Tribunal, 2016 to entertain
post-admission settlement applications, but this contention was challenged by both the Hon' ble
NCLAT and the Hon'ble Supreme Court in Lokh and wala Kataria Construction Private
Limited V. Nisus Financial and Investment Managers [2017 ] IBC law. in 04 SC.4 therefore
the Supreme Court, Judiciary and NCLAT have also in many cases proposed to the Parliament to
change the law so that it can decide on acceptance of cases. For example, in Uttara Foods and
Feeds Private Limited V. Mona Pharma chem [2017] IBC law.in 10 SC ("Uttara Foods
5
Case"). The Honourable Supreme Court rejected not only that the Adjudicating Authority
accepts after acceptance.

Application for compromise, relying on its jurisdiction under Rule 11 of the National Law Court
of Appeal Rules and on appeal to the Supreme Court its jurisdiction under Article 142 of the
Constitution, but also asked the parliament to change the law accordingly. Thus, both the
NCLAT and the Hon'ble Supreme Court, in the absence of any provision of law, allowed post-
entry settlement applications on their inherent authority as in Mothers Pride Dairy India
Private Limited V . Portrait Advertising and Marketing [2017] 6 IBC law in 05 SC.
Insolvency and Bankruptcy Regulation of India 30A (Process of Resolution of Insolvency of a
Corporate Person) Regulations, 2016 (IBBI IRPCP Regulations, 2016) as amended in 2019. The
application is made under section 12A through the IRP/Resolution Professional in Form FA and
before expressions of interest under rule 36A.The application must be accompanied by a bank
guarantee for costs assessed under rule 31 of the Insolvency Act. and the Insolvency Board of
India (Insolvency Resolution Process for Corporate Persons) Regulations, 2016 (hereinafter
referred to as "IBBI CIRP Regulations 2016")The COC will review the application within 7 days

4
[2017] ibc law. in 04 SC
5
[2017] ibc law .in 10 SC
6
[2017] ibc law.in 05 SC
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of its receipt or establishment and approve it through a single 90 % majority vote.After passing
the order, the Resolution Officer ruled against it. Rule 30A, which was not amended, required
that an application for annulment be made before an interest was expressed Rule 36A was
promulgated but the Supreme Court held that that sub-rule enumerated in Brilliant Alloys
Private Limited Vs. S. Rajagopal [2018]7 IBC law .in 35 SC where he said that the provision
that cancellation petition cannot be entertained after inviting expressions of interest is a
catalogue as it is outside the Constitution i.e. IBC because the parent Law contains no such
restrictions and therefore allows the annulment application.

Rule 30A of the IBBI Rules has been amended so that applications for cancellation of CIRP can
be considered even before the formation of the Participating Committee. Clarified that Rule 30
of IBBI Rules is not inconsistent with Chapter 12A of IBC; rather it supplements the provisions
of Section 12A of the IBC .Furthermore, the NCLT under Rule 11 of the NCLT Rules, 2016 has
the power to either allow or reject an application for cancellation of CIRP even before the
formation of an organization, CoC. Other creditors of the corporate debtor retain their
independent rights against the corporate debtor, which remain intact even if the agreement
between the corporate debtor and the operating creditor is accepted and the procedures are
entitled to be withdrawn.\due to the above-mentioned circumstances; the honourable Supreme
Court quashed the impugned order. In addition, he explicitly explained that his remarks do not
affect the rights of other creditors, who are free to present independent claims in appropriate
proceedings to be resolved according to the relevant provisions. In addition, the Supreme Court
in its judgment not only fixed the loophole in Section 12A of the IBC by confirming that the IBC
proceedings can be withdrawn before the establishment of the RKK, even if the CIRP is
initiated, but it also recognized the mandatory. . IBC status, Rule 30A of IBBI.

7
[2018] ibc law. in 35 SC
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  CURRENT POSITION – SECTION 12A OF THE IBC READ WITH
REGULATION 30A IBBI IRPCP REGULATIONS, 2016

Section 12A was inserted in the IBC by the Insolvency and Bankruptcy (Second Amendment)
Act, 2018 w.e.f. IBC on June 6, 2018, which authorizes the judicial authority to approve
applications completed under clauses 7, 9 or 10 by a 90% vote of the creditors' committee (COC)
at the request of the applicant. Section 12A uses the word "may", which gives discretion to the
public prosecutor to grant or refuse such requests. Section 12A was added to the IBC on the
recommendations of the Insolvency Law Committee (March 2018), which announced its report
that they could previously withdraw an application for admission by making an application to the
CIRP under Rule 8 of the Rules, but for post-admission applications they do not apply under the
IBC or any other such rule or regulation. On that basis, the court allows such cancellations, but
despite this, there are several cases where both the challenging authority and the NCLAT have
accepted such applications based on their own jurisdiction. In addition, the ILC relied on the
recommendations of the Bankruptcy Law Commission Report, which previously stated that "a
negotiated settlement must also full fill the obligations of creditors not involved in the
negotiation process". This means that if the insolvency power is granted, it will no longer be a
dispute between two parties, but will become a proceeding involving all the creditors of the
corporate debtor.

Once the application is approved, the IRP is appointed by the disputing authority under section
16 of the IBC, and upon his appointment, the IRP is entrusted with various statutory duties under
the IBC, such as public notification, service of summons against the corporate debtor. , formation
of the debtor. Committee of Creditors (COC) etc. The COC consists of only financial creditors,
but if the corporate debtor has no financial creditors, the COC would consist of operating
creditors. Boards of debtors of suspended companies are not allowed to vote in the decision of
the IOC, but they can attend and participate in the meetings of the commission. The meetings are
chaired by a resolution professional and only financial creditors have voting rights in the COC.

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The question of constitutionality of Section 12A came up in Swiss Ribbons Pvt. Ltd. V. Union
of India [2019] IBC law. in 03 SC where it was held that Section 12A of IBC is inconsistent
with the decision in Uttara Foods and Feeds Ltd. v. Mona Pharmachem [2017] IBC law .in
10 SC and it gives the COC unfettered and absolute right to decide such applications at its whim
and fancy and violates Article 14 of the Constitution of India. However, the Honourable
Supreme Court disagreed with this contention and said that Section 12A was constitutional in
reaching this conclusion, relying on the Insolvency Law Committee Report (2018) and noting
that the threshold for passing a COC was 90%. This is justified before a request for settlement is
made, as it is likely to encourage a joint settlement with all financial creditors, and it is also a
matter of policy what the appropriate criteria might be. In addition, the Honourable Supreme
Court said that whenever the COC arbitrarily rejects the cancellation petition, the aggrieved party
can also challenge the same under Section 60 of the IBC in the court, which may or may not
grant it or annul the decision of the COP.

If the COC constitutes an IPR then the COC has to pass the cancellation petition by 90% votes
but if the COC is not constituted then the IRP itself can file such a petition to cancel the CIRP as
happened in the case of Vinayak K. Deshpande V. Nexo Industries P .Ltd. (2022) IBC law .in
8
12 NCLAT wherein the Honourable NCLAT, allowing the post-acceptance arrangement,
directed the IRP to file Form FA under Section 12A of the IBC read with the corporate
insolvency resolution process under Rule 30A. Person) 2016 regulation in the challenged
authority and it also allowed the suspended board to regain control of the management of the
debtor company. It must be a bank guarantee in Form FA as laid down in the Regulatory
Schedule for two items viz. costs incurred up to the date of withdrawal in accordance with
Interim Resolution Professional Rule 33 . Under clauses aa, ab c and d of rule 31. The request for
withdrawal must be processed by the COC within 7 days after receiving it, or if the COC has not
been formed, the IRP must submit a request to the agreement authority within 3 days after
receiving it. After receiving the petition, the COC approves it with a 90 percent vote, and the IRP
then submits both the annulment petition and the COC's decision to the court. If the settlement

8
(2022) ibc law.in 12 NCLAT
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agency accepts the request, the applicant must pay the amount determined by the IRP within
three days.

 RECENT CASES

Satyanarayan Malu V. SBM Paper Mills Ltd. [2018] IBC law .in 01 NCLT An interesting
question of law arose before the Honourable NCLT, Mumbai asking whether a suspended
director of a debtor company under CIRP can file an application under Section 12A offering
lump sum. Arrangement after the resolution plan has been approved by the COC and it is
awaiting the approval of the conciliation board, the NCLT said yes but said that such late
applications should be rejected and penalty imposed. Rs. 5 lakhs to the petitioner for wasting
court time and initiating IBC. The application was accepted by the Honourable NCLT because
the OTS offered by the director was higher than that of the more successful resolution applicant
and also at that time the IBC CIRP 2019 amended regulation 2016 was not applicable to the
corporate debtor, hence the condition . That the winding up petition should have been executed
before the issuance of the expression of interest was not applicable in the facts of the case and
NCLT accepted the belated application.

Praveen Arjun Patel V. JK Lakshmi Cement Ltd. [2018] IBC law.in 57 NCLAT 9, the
Judicial Authority accepted an application under Section 9 filed by an operating creditor and
appointed IRP. Later, the corporate debtor appealed against the final order to the Honourable
NCLAT where the petitioner and the corporate debtor settled the matter and the CIRP was
closed. As by then the IRP claimed, the remaining creditors argued before the Honourable
NCLAT that the agreement violated Section 12A of the IBC, but the court did not agree with
their contention that Section 12A was not applicable. The KSK is still being formed and the final
decree was disputed and the final decree made by the court was annulled during the settlement,
therefore the request for annulment with the permission of other creditors was justified and the
court decree lacks the corresponding powers.
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[2018] ibc law .in 57 NCLAT
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In the case of Dinesh Gupta V. Rolta India Limited (2021) IBC Law 690 NCLT, the
Honourable NCLT, Mumbai was faced with the question whether a cancellation petition filed by
an applicant under Section 12A can be entertained if it was made earlier. After obtaining the
consent of the COC Rules and all the applicant, but matters have not been resolved with the
other creditors of the corporate debtor. Honourable NCLT considered the case of IBC, Swiss
Tape (supra) and observed that no petitioner has an inherent right to withdraw the petition after
admission even if the matter is settled between him and the corporate debtor as there is a
proceeding after admission. Rem and the interest of other stakeholders are also involved in the
case, he further noted that since in this case not only the debt was paid to the financial creditors,
but also most of the financial creditors of the corporate debtor are banks that paid large sums.
Loans to the debtor of the company, in addition, the challenged authority also stated that it
already has about 75 cases against the same company of the current exclusion of the applicant.
Considering these factors, the Honourable NCLT dismissed the application filed under Sec. 12A
as the same would lead to many proceedings in other creditors of the corporate debtor.

In Jai Kishan Gupta V. Green Edge and Ors IBC Law .in 240 NCLAT the Honourable NCLAT
dismissed the quashing petition under Section 12A and affirmed the decision of the Honourable
NCLT. There were other financial creditors who submitted their claims to the IRP: It will and
whose claims were not compensated by the corporate debtor, the Honourable NCLAT also
pointed out that the petitioner i.e. The ex-manager of the corporate debtor did not cooperate.
With the IRP. In the meantime, that is after the filing of the petition but before the settlement
authority decided on the same, the COC was constituted and therefore the Honourable NCLAT
opined that the COC should first approve the cancellation petition.

 CONCLUSION

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By introducing section 12A, the government sought to give legal recognition to a concept that
had already been recognized by the courts in several cases, viz. post-entry agreement. Pre-
admission arrangements were recognized as early as 2016 under Rule 8 (Application to
Adjudicating Authority) of the Insolvency and Bankruptcy Rules, but as the Act did not
recognize post-admission arrangements, such matters were decided by the Settlement Authority
using inherent powers and in some cases the Supreme Court exercised its constitutional powers
under Article 142 .When on the recommendations of the Supreme Court in the case of Uttara
Foods and on the recommendation of the Insolvency Law Committee, Section 12A was enacted.
Inserted in the IBC by the Insolvency and Bankruptcy (Second Amendment) Act, 2018 w.e.f.
June 6, 2018.

Conditions for submitting an agreement request depend on the stage of its submission, if it is
submitted before acceptance or before the formation of COC, then the agreement authority can
also allow it in its jurisdiction, but it is submitted after acceptance and after formation of COC, it
can be applied under IBC section 12A as per Rule 30A of IBBI IRPCP Rules 2016. Generally, a
settlement request approved by the settlement authority results in a win-win situation for all.
Stakeholders covered by the IBC, whether courts, financial creditors or the applicant, and unless
the authority considers that granting the application would violate any provision of the IBC, or
considers that the consent of all independent financial creditors has not been obtained. Finally, it
can also be mentioned that the commercial wisdom of the KOK to accept or reject the
cancellation request is not decisive, and their decision is subject to judicial review in the court,
which can grant or reject the cancellation request.

BIBLOGRAPHY

. https://insolvencyandbankruptcy.in/

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. https://www.lexology.com/

. https://ibclaw.in/

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