Resolution plan approval under insolvency law upheld where CoC process was followed and no statutory irregularity was shown.

A resolution plan that complied with Section 30(2) of the Insolvency and Bankruptcy Code and carried the required CoC approval was found fit for approval because the Resolution Professional submitted the prescribed certificate and supporting record, and the plan included the implementation, management, and supervision framework required for approval. Objections by rejected applicants alleging irregularity in selection, disclosure of bid details, and need for investigation failed because the statutory process had been followed and the adjudicating authority would not reopen the CoC's commercial decision or the rejection of competing plans absent proved non-compliance. The plan was approved under Section 31(1), made binding on stakeholders, and the moratorium ceased.

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Issues: Whether the resolution plan approved by the Committee of Creditors satisfied the statutory requirements for approval under the Insolvency and Bankruptcy Code 2016; whether the objections raised by rejected resolution applicants disclosed any legal irregularity warranting interference with the CoC process; and whether the resolution plan ought to be approved and made binding under Section 31(1).

Issue (i): Whether the resolution plan approved by the Committee of Creditors satisfied the statutory requirements for approval under the Insolvency and Bankruptcy Code 2016.

Analysis: The Resolution Professional placed the plan before the Bench with the requisite certificate and supporting record. The plan had been considered through multiple CoC meetings, and the Bench found that the Resolution Professional complied with the requirements of Section 30(2) and furnished the certificate contemplated by Regulation 39(4)(a). The plan also contained the implementation schedule, management framework, and supervision mechanism required for approval.

Conclusion: The resolution plan satisfied the statutory conditions for approval and was liable to be approved.

Issue (ii): Whether the objections raised by rejected resolution applicants disclosed any legal irregularity warranting interference with the CoC process.

Analysis: The objections related to alleged irregularity in selection, alleged disclosure of bid details, and request for investigation. The record showed that the competing plans were considered by the CoC in its meetings, that the relevant applicant's plan was rejected on account of belated submission, and that the plan approved by the CoC carried 100% voting share. The Bench held that it could not reopen the CoC's reasons for rejection where the statutory process had been followed, and that any grievance regarding the Resolution Professional could be pursued before the appropriate regulatory authority under Section 217.

Conclusion: No legal irregularity warranting interference was made out, and the objections were rejected.

Issue (iii): Whether the resolution plan ought to be approved and made binding under Section 31(1).

Analysis: Since the approved plan complied with the statutory requirements and the objections failed, there was no impediment to approval. Upon approval, the plan would bind the corporate debtor and its stakeholders, and the moratorium would cease to operate.

Conclusion: The resolution plan was approved under Section 31(1) and became binding on all stakeholders.

Final Conclusion: The corporate insolvency resolution process culminated in approval of the plan submitted by CP Ispat Private Limited, the objections of the rejected applicants failed, and the plan was directed to take immediate effect with consequential cessation of the moratorium.

Ratio Decidendi: Where a resolution plan complies with Section 30(2) of the Insolvency and Bankruptcy Code 2016 and is approved by the Committee of Creditors with the requisite voting share, the adjudicating authority will not reappraise the CoC's commercial decision or reopen the rejection of competing plans absent proved statutory non-compliance.

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