Operational creditors' rights in insolvency are limited to statute; no access to the resolution plan or participation in approval.

Operational creditors, including employees, were entitled only to the rights expressly conferred by the Insolvency and Bankruptcy Code and the regulations governing resolution, namely claim lodging, verification, and receipt of treatment under the plan. The statutory scheme did not confer any right to obtain a copy of the resolution plan before approval, to intervene in the approval proceedings, or to be heard by the Adjudicating Authority, and general principles of natural justice could not enlarge that limited entitlement. The confidentiality obligation under the insolvency regulations remained binding, so the resolution professional could not be compelled to disclose the plan. The applications were therefore rejected.

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Issues: (i) Whether employees and other operational creditors were entitled to obtain a copy of the resolution plan before its consideration by the Adjudicating Authority. (ii) Whether such stakeholders were entitled to intervene in, participate in, or be heard during the proceedings for approval of the resolution plan. (iii) Whether the resolution professional could be compelled to disclose the plan despite the statutory confidentiality regime.

Issue (i): Whether employees and other operational creditors were entitled to obtain a copy of the resolution plan before its consideration by the Adjudicating Authority.

Analysis: The resolution process under the Insolvency and Bankruptcy Code is structured so that the resolution plan is placed before the Committee of Creditors for commercial assessment and then before the Adjudicating Authority for approval. The employees of the corporate debtor were treated as operational creditors whose role in the process is limited to lodging and verification of claims and to receiving treatment under the plan in accordance with the statute. The statutory scheme and the confidentiality obligation imposed on insolvency professionals did not contemplate disclosure of the plan to operational creditors who were not members of the Committee of Creditors.

Conclusion: The applicants were not entitled to a copy of the resolution plan.

Issue (ii): Whether such stakeholders were entitled to intervene in, participate in, or be heard during the proceedings for approval of the resolution plan.

Analysis: The Code is a complete code and the Adjudicating Authority must act within its express framework. The statutory design does not confer any participatory role on operational creditors in the deliberations of the Committee of Creditors or in the approval process of the resolution plan, beyond the limited rights specifically provided by the statute. Reliance on general principles of natural justice could not override the express legislative scheme governing insolvency resolution.

Conclusion: The applicants were not entitled to intervene in or be heard during the approval proceedings.

Issue (iii): Whether the resolution professional could be compelled to disclose the plan despite the statutory confidentiality regime.

Analysis: Regulation 22 of the Insolvency and Bankruptcy Board of India (Insolvency Professionals) Regulations, 2016 requires maintenance of confidentiality, subject only to the limited exceptions provided by the Code and the regulations. Since the applicants did not fall within the class of persons statutorily entitled to receive the plan, the refusal to furnish it was justified.

Conclusion: No direction could be issued compelling disclosure of the resolution plan.

Final Conclusion: The applications failed because the statutory insolvency framework does not confer on operational creditors a right to receive the resolution plan or to participate in its approval process, and the confidentiality requirement remained binding.

Ratio Decidendi: In insolvency resolution, operational creditors are entitled only to the rights expressly conferred by the Code and regulations, and neither general principles of natural justice nor equitable considerations can expand those statutory entitlements to include disclosure of the resolution plan or participation in its approval.

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