Fresh slate principle bars belated insolvency claims; compliant resolution plans may still be approved despite procedural objections.

Belated claims and objections filed after approval of an earlier resolution plan cannot be revived once the insolvency process has advanced beyond the relevant stage, because a successful resolution applicant is entitled to proceed on a fresh slate. A limited reopening for fresh offers does not reopen the entire corporate insolvency process for new claims or redistribution objections. The resolution plan was also found compliant with the Insolvency and Bankruptcy Code: it provided for process costs, operational creditors, implementation, and statutory compliance, and no disqualification was established. Objections about the land lease, absence of a letter of intent, and the performance guarantee did not defeat approval, and the commercial decision of creditors was respected.

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Issues: (i) Whether belated claims and objections filed after approval of an earlier resolution plan could be entertained after the Supreme Court reopened only a limited window for fresh offers. (ii) Whether the committee of creditors approved resolution plan of DVI satisfied the requirements of the Insolvency and Bankruptcy Code and could be approved despite objections regarding ACE Complex land, absence of letter of intent, and incomplete performance bank guarantee.

Issue (i): Whether belated claims and objections filed after approval of an earlier resolution plan could be entertained after the Supreme Court reopened only a limited window for fresh offers.

Analysis: Claims not submitted or not accepted during the resolution process cannot be revived after approval of the resolution plan, as a successful resolution applicant is entitled to take over the corporate debtor on a fresh slate. The earlier directions of the Supreme Court merely permitted a limited fresh-bidding exercise and did not reopen the entire corporate insolvency process for submission or admission of fresh claims. Applications seeking admission of claims or modification of the distribution scheme after the relevant stage were therefore barred.

Conclusion: The belated claim-based applications were not maintainable and were rightly dismissed.

Issue (ii): Whether the committee of creditors approved resolution plan of DVI satisfied the requirements of the Insolvency and Bankruptcy Code and could be approved despite objections regarding ACE Complex land, absence of letter of intent, and incomplete performance bank guarantee.

Analysis: The plan was examined against the mandatory requirements of section 30(2) and section 31 of the Insolvency and Bankruptcy Code, including provision for insolvency resolution process costs, treatment of operational creditors, management and implementation of the plan, compliance with law, and absence of disqualification under section 29A. The objection concerning ACE Complex land did not defeat approval because the lease requirement was treated as an effective-date condition and the lease had already been executed before approval of the plan. The absence of a letter of intent and the balance performance bank guarantee did not justify rejection in the peculiar circumstances, and the resolution professional was directed to secure compliance within time. The plan otherwise satisfied the statutory requirements and the committee of creditors' commercial decision was respected.

Conclusion: The DVI resolution plan was approved, and the related objection application was dismissed.

Final Conclusion: The order upheld the resolution plan process, rejected the belated challenge to claims, and confirmed that the approved plan would bind all stakeholders while the corporate insolvency process stood concluded in accordance with law.

Ratio Decidendi: Once a resolution plan has been approved in accordance with the Insolvency and Bankruptcy Code, belated claims cannot be reopened, and the adjudicating authority will approve the plan if the statutory requirements are met and the committee of creditors' commercial wisdom is not shown to violate the Code.

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