Separate proof of claim is mandatory in liquidation; prior resolution-stage claims cannot replace the statutory filing requirement.

In liquidation under the Insolvency and Bankruptcy Code, 2016, operational creditors must file proof of claim separately with the liquidator in the prescribed form and manner; prior filing of claims during the corporate insolvency resolution process does not substitute for that requirement. The liquidation framework treats resolution and liquidation as distinct stages, provides a specific appeal against rejection of claims, and the limited relaxation under Regulation 19(4) for workmen and employees does not extend to operational creditors. Equitable grounds cannot override this mandatory statutory procedure, so the request to treat earlier resolution-stage claims as liquidation claims was rejected.

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Issues: Whether operational creditors who had filed claims during the corporate insolvency resolution process but failed to file claims during liquidation could seek treatment of those earlier claims as liquidation claims on equitable grounds.

Analysis: The liquidation regime under the Insolvency and Bankruptcy Code, 2016 treats corporate insolvency resolution process and liquidation as distinct stages. A claimant is required to submit proof of claim to the liquidator in the prescribed form and manner, and the liquidator is then required to verify and either admit or reject the claim within the prescribed time. The statutory scheme provides a specific appeal against rejection, and the special relaxation available for workmen and employees under Regulation 19(4) of the IBBI (Liquidation Process) Regulations, 2016 does not extend to operational creditors. The fact that claims were earlier filed in the corporate insolvency resolution process does not dispense with the separate requirement of filing claims in liquidation. The request to invoke equity was rejected because insolvency proceedings are governed by a time-bound statutory framework that does not permit judicial innovation to override the mandated procedure.

Conclusion: The operational creditors were not entitled to have their corporate insolvency resolution process claims treated as liquidation claims, and the application was rejected.

Ratio Decidendi: In liquidation under the Insolvency and Bankruptcy Code, 2016, proof of claim must be separately filed before the liquidator in accordance with the statutory procedure, and equitable considerations cannot be used to bypass that mandatory requirement for operational creditors.

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