Approved resolution plans cannot be recalled for belated claims, and late-filed insolvency claims cannot be revived after approval.

An approved resolution plan could not be recalled or set aside merely because a claimant alleged non-consideration of its dues or lack of hearing, since insolvency proceedings do not confer a general power of review and the limited rectificatory power applies only to mistakes apparent from the record. The tribunal found no such error, noted that the claimant had filed after approval of the plan, and observed that the plan already provided for its dues on the basis of the information memorandum. It also held that a belated claim cannot be revived after plan approval, and the adjudicating authority cannot direct reconsideration of a claim filed beyond the prescribed timeline.

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Issues: (i) Whether the order approving the resolution plan could be recalled or set aside on the ground that the applicant's claim was allegedly not considered and the applicant was not heard. (ii) Whether, after approval of the resolution plan, the Adjudicating Authority could direct the resolution professional to consider a claim filed beyond the prescribed timeline.

Issue (i): Whether the order approving the resolution plan could be recalled or set aside on the ground that the applicant's claim was allegedly not considered and the applicant was not heard.

Analysis: The Code does not provide a general power of review, and the limited rectificatory power referred to by the Tribunal under section 420 of the Companies Act, 2013 extends only to a mistake apparent from the record. The Tribunal found no such mistake in the approval order. It further noted that the applicant had filed its claim after approval of the resolution plan by the committee of creditors, and the plan already reflected provision for the applicant's dues on the basis of the information memorandum. On that footing, there was no basis to recall or set aside the approval order.

Conclusion: The request to recall or set aside the approval order was rejected.

Issue (ii): Whether, after approval of the resolution plan, the Adjudicating Authority could direct the resolution professional to consider a claim filed beyond the prescribed timeline.

Analysis: The Tribunal relied on the settled principle that the corporate insolvency resolution process proceeds on a fresh slate and that all claims must be submitted and decided within the statutory framework so that the resolution applicant knows the liabilities to be addressed. In light of the Supreme Court's rulings relied upon in the order, a belated claim cannot be introduced after the resolution plan has been approved, and the Adjudicating Authority cannot compel the resolution professional to reopen consideration of such a claim.

Conclusion: The Tribunal held that no direction could be issued to consider the belated claim.

Final Conclusion: Both applications failed on merits, and the approval process and the settled treatment of claims under the resolution plan were left undisturbed.

Ratio Decidendi: In insolvency resolution, absent a specific statutory review power or a mistake apparent from the record, an approved resolution plan cannot be recalled, and claims not submitted within the prescribed time cannot be revived or directed to be considered after the plan has been approved.

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