Post-winding-up interest for secured creditors is barred unless expressly permitted and surplus remains after full satisfaction of claims.

A secured creditor in winding up is not entitled to claim interest accruing after the date of winding up unless the governing rule or insolvency provision expressly allows it and there is surplus after full satisfaction of admitted claims. Rule 156 of the Companies (Court) Rules, 1959 applies only where there is no contract on interest and does not authorise post-winding-up interest. Section 47 of the Provincial Insolvency Act, 1920, read with Section 61(6), permits such interest only in the limited case of surplus distribution. Rule 179 likewise confines post-winding-up interest to surplus after full payment of claims admitted to proof.

---

---

Issues: Whether a secured creditor in liquidation is entitled to claim interest after the date of winding up under Rule 156 of the Companies (Court) Rules, 1959, or under the insolvency provisions applied through Section 47 of the Provincial Insolvency Act, 1920.

Analysis: Rule 156 applies only where there is no contract regarding payment of interest and does not authorise a secured creditor to claim interest after winding up. Section 47 of the Provincial Insolvency Act, 1920 does not permit post-adjudication interest to a secured creditor except to the limited extent contemplated by Section 61(6), where interest may be paid only if there is surplus after full distribution. Rule 179 of the Companies (Court) Rules, 1959 also makes it clear that interest after winding up can arise only if there is surplus after payment in full of claims admitted to proof.

Conclusion: The secured creditor was not entitled to interest after the date of winding up, and the liquidator's rejection of that claim required no interference.

Ratio Decidendi: In winding up or insolvency proceedings, a secured creditor is not entitled to post-winding-up interest unless the governing rule or insolvency provision expressly permits it and there is surplus after full satisfaction of admitted claims.

---