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Insolvency & IBC
Deependra Kumar SinghJuly 28, 202610 min read
Akros Legal Publication

Executive Summary

The commercial wisdom of the Committee of Creditors (CoC) remains the cornerstone of the Insolvency and Bankruptcy Code (IBC). This paper reviews recent appellate decisions balancing CoC primacy against statutory compliance and resolution plan viability.

1. The Sanctity of CoC Commercial Wisdom

The Supreme Court in landmark rulings including K. Sashidhar and Essar Steel established that adjudicating authorities (NCLT/NCLAT) cannot evaluate the commercial viability of a resolution plan approved by the CoC with a 66% voting majority.

However, recent appellate jurisprudence underscores that this immunity is conditional upon strict compliance with Section 30(2) of the Code, including fair treatment of operational creditors.

2. Adjudicating Authority Oversight vs. Overreach

While NCLT cannot alter commercial terms, it retains jurisdiction to remit resolution plans back to the CoC if procedural irregularities, statutory non-compliance, or Section 29A disqualifications are identified.

Key Practice Takeaways

CoC commercial decisions are non-justiciable provided statutory requirements under Sec 30(2) are satisfied.
Operational creditors must receive non-discriminatory minimum liquidation values.
Early Section 29A eligibility clearance prevents post-approval litigation delays.
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