Liquidation must remain revival-oriented first, with compromise or arrangement explored before any outright sale of assets.

In liquidation under the insolvency framework, liquidation is a last resort and revival through compromise or arrangement must be explored before outright sale of the corporate debtor's assets. Where no resolution plan had been approved and the statutory period had expired, interference with the liquidation order was not warranted, but the liquidator was still required to attempt a section 230 Companies Act process to assess possible revival and value maximisation. The liquidation order was therefore left undisturbed, with directions to proceed first with revival-oriented steps before any final sale of assets.

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Issues: Whether the liquidation order should be interfered with and whether the liquidator should be directed to explore revival of the corporate debtor under section 230 of the Companies Act, 2013 before sale of assets.

Analysis: No resolution plan had been approved and the statutory period had expired, so interference with the liquidation order was not warranted. At the same time, liquidation under the insolvency framework is a last resort, and the liquidation process must still be used to explore revival and continuation of the corporate debtor where possible. The statutory scheme permits the liquidator to take custody and control of assets, verify claims, and proceed in accordance with the insolvency code, but before outright sale of the corporate debtor's assets, steps for compromise or arrangement under section 230 of the Companies Act, 2013 must be attempted. The liquidation process should therefore aim at maximisation of assets, protection of stakeholders, and revival if a viable arrangement can be achieved.

Conclusion: The liquidation order was not interfered with, but the liquidator was directed to proceed under section 230 of the Companies Act, 2013 and to attempt revival before any outright sale of the corporate debtor's assets.

Final Conclusion: The appeal ended with directions preserving the liquidation order while requiring a revival-oriented process through compromise or arrangement before final sale of the corporate debtor's assets.

Ratio Decidendi: In liquidation under the insolvency code, revival through compromise or arrangement must be explored before outright sale of the corporate debtor's assets, because liquidation is a last resort and the statutory object is to maximise value and facilitate continuation where feasible.

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