Assignment-based creditor claims in insolvency require valid registration and proof of consideration before CoC admission.

An assignee seeking recognition as a financial creditor in insolvency must establish a valid assignment before the Resolution Professional, including registration where required and satisfactory proof of consideration. If the claim is made before the deed is registered and the transfer of consideration is not properly shown, the Resolution Professional may decline to act on the assignment for Committee of Creditors admission. The assignee can step into the assignor's shoes only to the extent supported by the facts, and an assignor's related-party status that has already attained finality remains relevant to the claim's treatment.

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Issues: Whether the assignee of debt, derived from a creditor already held to be a related party, was entitled to be recognised as a financial creditor and included in the Committee of Creditors when the assignment deed was unregistered at the time the claim was made and proof of payment of consideration was not satisfactorily shown.

Analysis: The earlier order holding the original creditor to be a related party had attained finality. The assignment covered receivables and not the shares, but the assignee nevertheless sought entry into the Committee of Creditors on the basis of that assignment. The claim was made before the Resolution Professional when the assignment deed had not yet been registered, and the assignee did not renew the claim after registration. The record also did not satisfactorily establish receipt of the stated consideration by the assignor. In these circumstances, the Resolution Professional was justified in not acting upon the assignment for admission of the claim at that stage. The Court also observed that the assignee could, on proper proof, stand in the shoes of the assignor only to the extent permissible in the facts of the matter.

Conclusion: The assignee was not entitled to immediate recognition as a financial creditor in the Committee of Creditors on the basis of the assignment placed before the Resolution Professional, and the rejection of the application was upheld.

Final Conclusion: The appellate challenge failed, and the order refusing to act upon the assignment for CoC admission was sustained.

Ratio Decidendi: Where a claim based on assignment is presented to the Resolution Professional before the assignment deed is registered and the transfer of consideration is not satisfactorily established, the Resolution Professional may decline to recognise the assignee for admission in the insolvency process, especially when the assignor's related-party status has already attained finality.

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