{"id":1435,"date":"2026-05-04T08:05:28","date_gmt":"2026-05-04T08:05:28","guid":{"rendered":"https:\/\/theleagle.in\/?p=1435"},"modified":"2026-05-04T08:08:12","modified_gmt":"2026-05-04T08:08:12","slug":"bhushan-steel-i-case-understanding-the-supreme-courts-liquidation-order","status":"publish","type":"post","link":"https:\/\/theleagle.in\/?p=1435","title":{"rendered":"Bhushan Steel – I Case | Understanding the Supreme Court\u2019s Liquidation Order"},"content":{"rendered":"
<\/div>\n

Preliminary (Quiz) Notes<\/u><\/strong>: <\/p>\n\n\n\n

This is a two-part series on the Bhushan Steel saga. In Part-I, I discuss the Supreme Court\u2019s – now recalled \u2013 first judgment where it decided to liquidate Bhushan Steel. In Part-II<\/a>, I discuss the Supreme Court\u2019s subsequent decision to rescue Bhushan Steel.\u00a0\u00a0\u00a0<\/p>\n\n\n\n

I\u2019ve created two accompanying quizzes: <\/p>\n\n\n\n

Quiz-1, aligned to Part-I – Bhushan Steel (Recalled) Judgment \u2013 Fill in form<\/a> and,<\/p>\n\n\n\n

Quiz-2, aligned to Part-II \u2013 Quiz-2: Bhushan Steel (Subsequent) Judgment  \u2013 Fill in form<\/a><\/p>\n\n\n\n

Use these quizzes to self-assess your knowledge about these cases. Admittedly, some of the quiz questions go beyond what is discussed in the articles. Choose, whether you want to attempt the quizzes before or after reading the articles!  <\/p>\n\n\n\n

Introduction<\/strong><\/p>\n\n\n\n

On 2nd<\/sup> May 2025, the Supreme Court in Kalyani Transco v M\/S Bhushan Power and Steel Ltd<\/a> & Ors (\u2018Bhushan Steel-I case\u2019) directed the National Company Law Tribunal (\u2018NCLT\u2019) to initiate liquidation proceedings against the corporate debtor, i.e., Bhushan Steel. Supreme Court\u2019s decision was based on multiple factors that had a common theme: disrespect and violation of the procedures and timelines prescribed under the Insolvency and Bankruptcy Code, 2016 (\u2018IBC\u2019). And almost all entities involved in the Corporate Insolvency Resolution Process (\u2018CIRP\u2019) were, as per the Supreme Court, guilty of disregarding their statutory duties: the resolution professional, the Committee of Creditors (\u2018CoC\u2019), successful resolution applicant, the NCLT and the National Company Law Appellate Tribunal (\u2018NCLAT\u2019). <\/p>\n\n\n\n

In this article, I proceed as follows: in Part A, I provide an overview of the judgment and summarize five parameters that the Supreme Court relied on to liquidate the corporate debtor; in Part B, I discuss a few implications of the judgment and the lessons it offers us even if it has been recalled; and, finally in Part C, I mention the Supreme Court\u2019s reason to accept the review petition and recall the judgment.   <\/p>\n\n\n\n

Part A: An Overview of the Judgment <\/strong><\/p>\n\n\n\n

I. Suppression of Facts about Disqualification under Section 29A<\/strong><\/p>\n\n\n\n

To begin with, the Supreme Court pointed out that the resolution professional \u2013 and thereafter the CoC and the NCLAT – did not discharge their duty of verifying that JSW, the successful resolution applicant, was eligible to submit a resolution plan under Section 29A. Regulation 39(1), Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) Regulations, 2016 (\u2018CIRP Regulations\u2019) requires a resolution applicant to submit a resolution plan along with an affidavit stating that it is eligible to submit a resolution plan under Section 29A. The resolution professional is required to certify that the resolution applicant has filed such an affidavit and submit a compliance certificate in \u2018Form H\u2019. The Supreme Court noted that the resolution professional did not complete this obligation. Also, the resolution professional did not submit the certificate or produce any statement about eligibility of the resolution applicant. The omission of compliance certificate, as per the Supreme Court, raised serious doubts about eligibility of JSW to submit a resolution plan. What added to the Supreme Court\u2019s doubt was that the NCLAT \u2018encouraged suppression of facts\u2019 about JSW\u2019s ineligibility to submit a resolution plan under Section 29A. The ineligibility had apparently arisen due to a prior joint venture agreement between JSW, Bhushan Steel, and Jai Balaji. Which evidently made JSW a \u2018related party\u2019 to Bhushan Steel and ineligible to submit a resolution plan under Section 29A. But the Supreme Court said that the NCLAT sought to justify suppression of facts by JSW about its ineligibility thereby contravening the IBC. But the Supreme Court did not specify how exactly the NCLAT encouraged suppression of facts about the ineligibility.      <\/p>\n\n\n\n

II. Right of Appeal Only on Limited Grounds <\/strong><\/p>\n\n\n\n

Section 61 of the IBC grants a right to \u2018any person aggrieved\u2019 by the NCLT\u2019s order to file an appeal to the NCLAT. And Section 62 uses the same expression for an appeal to the Supreme Court against an order of the NCLAT. Thus, there is no rigid locus requirement to institute an appeal to the NCLAT or to the Supreme Court. The Supreme Court in Bhushan Steel-I case held that CIRP proceedings are in rem and all stakeholders are permitted to file an appeal before the NCLAT or the Supreme Court. And erstwhile promoters and successful resolution applicants are stakeholders in a CIRP. To this effect, the Supreme Court relied on a similar interpretation adopted in GLAS Trust Company LLC v BYJU Raveendran & Ors<\/a>.  However, the Supreme Court pointed out that an appeal can be filed only on the grounds specified in Section 61 or Section 62, whichever is applicable.  <\/p>\n\n\n\n

In the impugned case, the NCLT had approved the resolution plan of JSW, but subject to certain conditions. JSW, despite its plan being approved, filed an appeal in the NCLAT against the NCLT\u2019s decision. This was unusual and the Supreme Court disapproved the NCLAT hearing this appeal for three reasons. <\/p>\n\n\n\n

Firstly, the Supreme Court noted that since the NCLT approved JSW\u2019s resolution plan:<\/p>\n\n\n\n

\u2018Hence, JSW as such, could not be said to be the \u201cperson aggrieved\u201d by the order of NCLT approving the Resolution Plan of JSW itself.<\/em>\u2019 (para 14)       <\/p>\n\n\n\n

But JSW was aggrieved by some conditions imposed by the NCLT while approving the resolution plan. Thus, we can make an argument that JSW could legitimately claim status of an aggrieved person despite being the successful resolution applicant. <\/p>\n\n\n\n

Secondly, the Supreme Court noted that none of the grounds for appeal enlisted in Section 61(3) existed. Thus, JSW could not have filed an appeal before the NCLAT. <\/p>\n\n\n\n

Thirdly, the Supreme Court added that the NCLAT erred in admitting JSW\u2019s appeal which was not legally maintainable. And the NCLAT then compounded this error by modifying conditions in the resolution plan as requested by JSW. The Supreme Court particularly failed to understand the NCLAT\u2019s directions where it declassified Bhushan Steel as a promoter of another company – Nova Iron Steel. The NCLAT noted whether Bhushan Steel has 25.6% shareholding in Nova Iron Steel is a question of fact. But \u2018if there is any such share\u2019 Bhushan Steel on approval of the resolution plan declassified as a promoter. The NCLAT\u2019s power to issue such an order declassifying promoter and the rationale for the order were correctly questioned by the Supreme Court. <\/p>\n\n\n\n

III. Vacation of Attachment Order Nullified  <\/strong><\/p>\n\n\n\n

Five days after the NCLT approved the resolution plan of JSW, Directorate of Enforcement provisionally attached assets of Bhushan Steel under Section 5 of The Prevention of Money-Laundering Act, 2002 (\u2018PMLA\u2019). The NCLAT declared the attachment as illegal and without jurisdiction. The Supreme Court held that it was the NCLAT instead that did not have jurisdiction to vacate an attachment imposed under a public law such as the PMLA. <\/p>\n\n\n\n

The Supreme Court observed that the NCLT and the NCLAT were creatures of the statute, i.e. Companies Act, 2013. And jurisdiction of both bodies is circumscribed under Section 31 and Section 60 of the IBC. And neither of the two entities have powers of judicial review over decision taken by a statutory authority in the realm of public law. In this respect the Supreme Court relied on M\/S Embassy Property Developments Private Limited v State of Karnataka & Ors<\/a> (\u2018Embassy Property case\u2019). In Embassy Property case, the Supreme Court had interpreted scope of Section 60(5) which provides jurisdiction to the NCLT on any question of law or facts \u2018arising out of or in relation to the insolvency resolution \u2026\u2019. The Supreme Court held that a decision by a statutory authority in the realm of public law cannot be brought within the fold of \u2018arising out of or in relation to the insolvency resolution\u2019. And, if the corporate debtor must exercise a right that falls outside the purview of IBC, they cannot go to the NCLT for enforcement of such a right. Only the relevant public law framework must determine the rights and not the IBC. <\/p>\n\n\n\n

Based on ratio of the Embassy Property case and scope of Section 60(5), the Supreme Court held that: <\/p>\n\n\n\n

The PMLA being a Public Law, the NCLAT did not have any power or jurisdiction to review the decision of the Statutory Authority under the PMLA<\/em>. (para 30)<\/p>\n\n\n\n

The Supreme Court thus declared the NCLAT\u2019s order of vacating the attachment as without any authority of law and without jurisdiction. Also, the attachment order issued under the PMLA was subject matter of challenge before the Supreme Court in the Special Leave Petitions filed by the CoC. The Supreme Court had stayed the attachment order. But, despite that the NCLAT went ahead and reviewed orders of attachment and recorded findings on Section 32A. The Supreme Court frowned upon the NCLAT\u2019s approach where it did not defer to the Supreme Court and did not wait for it to pass its final decision on the issue.     <\/p>\n\n\n\n

IV. The CoC\u2019s Role and Conduct <\/strong><\/p>\n\n\n\n

The CoC, as per the Supreme Court performed a questionable role in CIRP on three counts: approving a resolution plan that did not incorporate mandatory conditions prescribed by the IBC, a handful of financial creditors granting extensions to JSW during implementation of the resolution plan, and a change in its stance about the resolution applicant\u2019s conduct especially delays in implementing the resolution plan.  <\/p>\n\n\n\n

The Supreme Court examined the resolution plan and held that it contravened a mandatory condition under Section 30(2)(b) of the IBC, i.e., the operational creditors must be paid on priority. And despite the resolution plan not providing for priority payments to operational creditors the resolution professional and the CoC approved it. Equally, the Supreme Court emphasized other mandatory requirements: completing CIRP within the time prescribed under Section 12, ensuring compliance of Section 29A, ensuring that the resolution plan is feasible and viable, and that the resolution applicant had capability to implement the resolution plan within the time limit are mandatory requirements under the IBC read with relevant CIRP Regulations. But the Supreme Court questioned if the CoC had exercised its commercial wisdom in approving the resolution plan which was in violation of various mandatory conditions and held that: <\/p>\n\n\n\n

If the Resolution Plan does not comply with such mandatory requirements and such plan is approved by the CoC, it could not be said that the CoC had exercised its commercial wisdom while approving such Resolution Plan<\/em>. (para 73)  <\/p>\n\n\n\n

While commercial wisdom of the CoC is non-justiciable but if the CoC\u2019s decisions are in contravention of the IBC, courts can and should intervene. And the Supreme Court in Bhushan Steel-I case justified its review of the CoC\u2019s decision by pointing at various violations of the IBC. <\/p>\n\n\n\n

The Supreme Court also questioned the CoC\u2019s role during the implementation phase of the resolution plan. The CoC its affidavit had levied multiple allegations against the JSW and its conduct including but not limited to delay in upfront payments, willful breach of the resolution plan, misuse of the legal process, and CIRP taking more than 35 months in a high-stake corporate insolvency case. However, when JSW, at a belated stage \u2013 after almost two and a half years – offered the upfront amount, the CoC accepted it without any demurrer. Even though the effective date for implementation of the resolution plan had expired. The Supreme Court taking note of the CoC\u2019s change in stance concluded that it lacked bona fide, had played foul and not exercised its commercial wisdom in the interest of creditors. And the Supreme Court concluded that JSW also delayed implementation of the resolution plan, unjustly enriched itself and thereafter when the market conditions were suitable, it complied with the resolution plan by colluding with the CoC and the resolution professional.  <\/p>\n\n\n\n

Finally, under the resolution plan, JSW had agreed to infuse equity for an amount of Rs 8550 crores in the corporate debtor on the effective date. However, the Supreme Court noted that apart from averments of the advocates, there was no material to show that the resolution applicant had fulfilled the condition of infusing equity. And, if the effective date for equity infusion was extended, the Supreme Court questioned as to who approved the extension. The reason for this question was that as per the Supreme Court the CoC had become functus officio on the NCLT\u2019s approval of resolution plan. Thus, some financial creditors claiming to be part of the CoC had no authority to grant an extension after the NCLT\u2019s approval. This was despite there being clarity that the resolution plan permitted the CoC to grant time extension to the successful resolution applicant. But the Supreme Court was convinced that the CoC becomes functus officio on the NCLT\u2019s approval of the resolution plan. But it did not elaborate as to why and as per which provisions of the IBC did the CoC become functus officio.  <\/p>\n\n\n\n

V. Failure of Resolution Professional and Breach of Timelines<\/strong><\/p>\n\n\n\n

The resolution professional\u2019s various omissions are mentioned in significant detail in the judgment. I\u2019ve referred to the oversight in ensuring eligibility of the resolution applicant in sub-section I above. But fatal omission of the resolution professional, as per the Supreme Court, was not obeying timelines prescribed in the IBC and not following the prescribed procedures. For example, the resolution professional did not seek an extension from the NCLT when CIRP was not completed within the time prescribed under Section 12. Further, the resolution professional provided no justification as to why once the CoC had approved the resolution plan; it waited for four months to seek the NCLT\u2019s approval. Especially since the maximum period for completing CIRP had expired when application for the NCLT\u2019s approval was filed. Taking the view that completion of CIRP within the prescribed time is mandatory, the Supreme Court held that: <\/p>\n\n\n\n

In that view of the matter, we have no hesitation in holding that the Application submitted by the Resolution Professional seeking approval of the Resolution Plan of JSW under Section 31 being hit by Section 12 of IBC, the NCLT had committed grave error of law in approving the said plan<\/em> \u2026 (para 57)   <\/p>\n\n\n\n

Based on all the aforementioned factors, the Supreme Court rejected the resolution plan submitted by JSW. And directed the NCLT to initiate liquidation proceedings against the corporate debtor under Section 33 of the IBC. <\/p>\n\n\n\n

Part B: Implications of Bhushan Steel-I Case <\/strong><\/p>\n\n\n\n

I. Entire IBC Ecosystem under the Scanner <\/strong><\/p>\n\n\n\n

The Supreme Court in Bhushan Steel-I case revealed various flaws in the IBC\u2019s ecosystem. The CoC and the resolution professional seemed to have acted in contravention of or at least were casual in fulfilling their statutory duties. One reason for this was lack of any meaningful oversight from the judicial authorities. The NCLT and the NCLAT did not properly scrutinize their actions on the touchstone of legality. The judgment also revealed the lack of clear duties and roles during implementation of the resolution plan. The CoC, as per the Supreme Court ceased to exist once the NCLT approved a resolution plan. Thus, leaving no meaningful entity to oversee implementation and compliance with the resolution plan. In several paragraphs of the judgment there are various grains of truth that should have and still should be fruit of contemplation for the policy makers and the Insolvency and Bankruptcy Board of India (\u2018IBBI\u2019). Though there have been some changes in regards to implementation of the resolution plan.    <\/p>\n\n\n\n

II. Timelines Overpower the IBC <\/strong><\/p>\n\n\n\n

Breach of the IBC\u2019s prescribed timelines is stale news and reasons for delay may not have an immediate cure. But it is worth contemplating to what extent should the breach of timelines be judicially tolerated and what should be consequence of the breach. Which is better: timely liquidation or a prolonged attempt at rescuing the corporate debtor? The Supreme Court in Bhushan Steel-I case preferred liquidation. The IBC\u2019s design has been recently altered to restore CIRP and delay liquidation if rescue of the corporate debtor is possible. But it may not be ideal as I\u2019ve previously argued elsewhere<\/a>. While the Supreme Court in various judgments has exhorted importance of time in the IBC, what should be the ideal judicial approach if timelines are breached is still a big unknown. In Bhushan Steel-I case, the Supreme Court preferred liquidation due misconduct of all entities involved and because it took the view that timelines under the IBC are mandatory and not directory. Also, because JSW tried to present a fait accompli by delaying implementation of the resolution plan.     <\/p>\n\n\n\n

III. Conduct of the CoC and the Resolution Professional Needs Guardrails <\/strong><\/p>\n\n\n\n

The Supreme Court in Bhushan Steel-I case also revealed that while the resolution professional and the CoC have crucial roles in the IBC, the guardrails for ensuring that they perform their duties adequately are missing. Ideally, the NCLT and the NCLAT should act as a check on any tendency to derelict duty, but that did not happen in this case. The IBBI can initiate disciplinary proceedings against the resolution professional, but it may prove to be ineffective unless it takes place in a timely fashion and has a deterrent effect.  Equally, while there has been some attempt to bring more transparency in working of the CoC by mandating it to record reasons for its approval<\/a>. But there has been a simultaneous expansion of its responsibilities that inter alia involve overseeing liquidation. Encouraging transparency though is likely to infuse more confidence in the integrity of CIRP. But it comes with the danger of more challenges and judicial authorities slipping into the territory of reviewing commercial wisdom of the CoC. <\/p>\n\n\n\n

IV. Checking Bona Fides of the Resolution Applicant <\/strong><\/p>\n\n\n\n

Finally, the challenge of holding the successful resolution applicant accountable was also revealed by the Bhushan Steel-I case. While the IBC has been recently amended to allow for a more structured supervision of the resolution plan. And by extension conduct of the successful resolution applicant. However, it is undeniable that delays in implementation of the resolution plan due to a recalcitrant resolution applicant can upturn the entire CIRP<\/a>. Thus, ensuring bona fides of the resolution applicant and their capacity to implement the resolution plan ex ante is crucial instead of sacrificing the corporate debtor at the altar of liquidation due to failure in implementing the resolution plan. It was partly due to oversight in ex ante verification of the resolution applicant\u2019s bona fide that the implementation of resolution plan was delayed which prompted the Supreme Court to order liquidation. While there are adequate safeguards in the IBC in this respect \u2013 especially Section 29A \u2013 ensuring compliance with its mandate needs to be insisted without fault.          <\/p>\n\n\n\n

Caveat: The caveat for the entire set of comments above is, of course, that the judgment was recalled. Though, in my view, an academic purpose is still served by commenting on a recalled judgment. <\/p>\n\n\n\n

Part C: Recall of the Judgment   <\/strong><\/p>\n\n\n\n

Approximately three months after the judgment in Bhushan Steel-I case, the Supreme Court accepted the review petition<\/a>which challenged correctness of the judgment. The Supreme Court found that it was a \u2018fit case for recalling the judgment under review and reconsidering the matter afresh.\u2019 The Supreme Court, in its brief order, mentioned that in Bhushan Steel-I case: (a) various incorrect factual aspects were taken into consideration; and (b) arguments which were not advanced were considered while delivering the judgment.  <\/p>\n\n\n\n

The judgment in Bhushan Steel-I case had already been stayed, but acceptance of the review petition was a final nail in the coffin. And recall of the judgment ensured that all questions of law remained open for both parties to argue at the stage of final hearing.<\/p>\n\n\n\n

Which brings us to Part-II<\/a> and the Supreme Court\u2019s judgment where it rescued Bhushan Steel instead of liquidating it.\u00a0\u00a0<\/p>\n","protected":false},"excerpt":{"rendered":"

Preliminary (Quiz) Notes:  This is a two-part series on the Bhushan Steel saga. In Part-I, I discuss the Supreme Court\u2019s – now recalled \u2013 first judgment where it decided to liquidate Bhushan Steel. In Part-II, I discuss the Supreme Court\u2019s subsequent decision to rescue Bhushan Steel.\u00a0\u00a0\u00a0 I\u2019ve created two accompanying quizzes:  Quiz-1, aligned to Part-I … Read more<\/a><\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_themeisle_gutenberg_block_has_review":false,"cybocfi_hide_featured_image":"","footnotes":""},"categories":[198],"tags":[338,95,348,343,94,32],"class_list":["post-1435","post","type-post","status-publish","format-standard","hentry","category-abc-of-ibc","tag-bhushan-steel","tag-ibc","tag-insolvency","tag-liquidation","tag-ravpratapsingh","tag-supreme-court"],"yoast_head":"\nBhushan Steel - I Case | Understanding the Supreme Court\u2019s Liquidation Order - TheLeagle | Eco Law Forum<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/theleagle.in\/?p=1435\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Bhushan Steel - I Case | Understanding the Supreme Court\u2019s Liquidation Order - TheLeagle | Eco Law Forum\" \/>\n<meta property=\"og:description\" content=\"Preliminary (Quiz) Notes:  This is a two-part series on the Bhushan Steel saga. 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