Liquidation must remain revival-oriented, with Section 230 compromise explored before asset sale to preserve a going concern.

Liquidation was not interfered with because no viable resolution plan had emerged after publication of the information memorandum, but liquidation was treated as a last resort. The corporate debtor should, as far as possible, be kept alive as a going concern during liquidation, and the liquidator must first verify claims, take custody and control of assets, and then explore compromise or arrangement under Section 230 of the Companies Act, 2013 before any sale of assets. The earlier Section 391 approach under the Companies Act, 1956 was noted only as supporting the same revival-oriented principle.

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Issues: Whether the liquidation order required interference, and whether steps under Section 230 of the Companies Act, 2013 had to be undertaken during liquidation for possible revival of the corporate debtor.

Analysis: The record showed that the information memorandum had been published and no viable resolution plan had emerged, so the liquidation order was not disturbed. At the same time, liquidation was treated as a last resort and not the preferred outcome. The reasoning emphasised that the corporate debtor should, as far as possible, be kept alive as a going concern even during liquidation. For that purpose, the liquidator was required to verify claims, take custody and control of assets, and then proceed in accordance with the statutory scheme, including exploring compromise or arrangement under Section 230 of the Companies Act, 2013 before any sale of assets. The earlier law under Section 391 of the Companies Act, 1956 was noted only as supporting the same revival-oriented approach.

Conclusion: The liquidation order was upheld, but the liquidator was directed to first explore revival through Section 230 proceedings and to ensure continuation of the corporate debtor as a going concern during liquidation.

Final Conclusion: The appeals did not succeed in upsetting the liquidation, but the order was supplemented with directions preserving the possibility of revival through compromise or arrangement before liquidation assets are sold.

Ratio Decidendi: In liquidation, revival-oriented measures must be exhausted first, and the liquidator should explore compromise or arrangement under Section 230 of the Companies Act, 2013 while keeping the corporate debtor as a going concern before resorting to sale of assets.

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