Approved resolution plan implementation requires creditors to release title deeds and NOC, with limited protective restraint on asset alienation.

An approved resolution plan must be implemented by all stakeholders, and financial creditors were required to act in aid of that implementation by handing over the original title deeds, issuing the no objection certificate, and releasing the pledge of shares. To protect creditor and stakeholder interests while giving effect to the plan, the Tribunal also imposed a limited restraint preventing alienation of the corporate debtor's properties without prior specific leave. The application was disposed of by enforcing the approved plan together with this ancillary protective direction, which was not to defeat the plan but to secure compliance.

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Issues: Whether the financial creditors were required to hand over the original title deeds and issue the no objection certificate in terms of the approved resolution plan, and whether any protective direction was required to prevent alienation of the corporate debtor's properties.

Analysis: The dispute arose in the course of implementation of the approved resolution plan. The original title deeds were being retained by the financial creditors, but the resolution plan required their release in favour of the successful resolution applicant. The Tribunal noted the repeated directions earlier issued in the matter, the decision of the creditors' meeting, and the need to give effect to the approved plan. At the same time, the Tribunal accepted the apprehension expressed by the financial creditors and considered it necessary to protect their interest and the interests of other stakeholders by restricting disposal of the properties without leave of the Tribunal.

Conclusion: The financial creditors were directed to hand over the original title deeds, issue the no objection certificate, and release the pledge of shares, while the successful resolution applicant was restrained from alienating the properties without prior specific order of the Tribunal.

Final Conclusion: The application was disposed of by enforcing the approved resolution plan with a limited protective restraint to safeguard creditor interests.

Ratio Decidendi: Once a resolution plan has been approved, the stakeholders are bound to act in aid of its implementation, and the Tribunal may issue ancillary protective directions to ensure compliance without defeating the plan.

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