Approved resolution plans cannot be extended or reviewed absent express statutory power under the insolvency framework.

A sanctioned rehabilitation scheme under the repealed SICA regime, even if treated as a deemed resolution plan under the Insolvency and Bankruptcy Code, 2016, cannot be extended or reviewed in the absence of express statutory power. The governing principle is that once a plan is approved, the Code does not itself confer any general authority to reopen, enlarge, or review it. On that basis, a request to continue or modify the sanctioned scheme beyond its approved terms is not maintainable.

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Issues: Whether a sanctioned rehabilitation scheme under the Sick Industrial Companies (Special Provisions) Act, 1985, treated as a deemed resolution plan after repeal, could be extended or reviewed in the absence of any express provision for review under the Insolvency and Bankruptcy Code, 2016.

Analysis: The appeal arose from a refusal to extend the period of an already sanctioned scheme. The scheme had been prepared under the SICA regime and, after repeal, was sought to be continued on the footing that the saving and deeming provisions preserved it as an approved resolution plan. The Court noted that even if such a scheme were treated as a resolution plan under Section 31(1) of the Insolvency and Bankruptcy Code, 2016, the Code does not provide for review or extension of a plan once approved. In that situation, the absence of statutory power to reopen or enlarge the approved scheme was decisive.

Conclusion: The request for extension or review of the sanctioned scheme was not maintainable, and the appeal failed.

Ratio Decidendi: A sanctioned scheme, once treated as a resolution plan under the Insolvency and Bankruptcy Code, 2016, cannot be extended or reviewed unless the governing statute expressly confers such power.

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