Limited recall jurisdiction in CIRP bars merits review; natural justice and jurisdiction objections failed.

Recall applications in CIRP are maintainable only in narrow situations such as procedural error or fraud, and cannot be used as a substitute for review on merits. The admission order was passed after supersession of the board and in the presence of the Administrator, so no breach of natural justice was shown. The Adjudicating Authority was held to have jurisdiction to entertain the application under the insolvency framework for financial service providers, and the challenge based on the statutory insolvency bar was treated as an attempt to reopen the merits of admission. With appellate remedies already exhausted and the resolution plan having progressed, no ground for recall or interference was established.

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Issues: Whether the recall applications seeking recall of the admission order in the CIRP proceedings were maintainable, and whether the Adjudicating Authority had any error warranting recall on the grounds of natural justice, alleged lack of jurisdiction, or Section 10A bar.

Analysis: The recall power is confined to limited circumstances such as procedural error or fraud and cannot be used as a substitute for review on merits. The admission order was passed after supersession of the board and presence of the Administrator, so no violation of natural justice was made out. The Adjudicating Authority had jurisdiction to entertain the RBI's application under the insolvency framework for financial service providers, and the challenge based on Section 10A was, in substance, an attempt to reopen the merits of the admission order. The appellant had already pursued appellate remedies unsuccessfully, and the recall applications were filed much later with the same core grounds. The Tribunal also noted that the resolution plan had progressed and that the proceedings had become infructuous in practical terms.

Conclusion: The recall applications were not maintainable and no ground for interference with the impugned order was established.

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