Resolution plan approval extinguishes pre-approval claims and bars continuation of covered proceedings under insolvency law.

Approval of a resolution plan under the Insolvency and Bankruptcy Code, 2016, in conformity with section 30(2) and the CIRP Regulations, binds the corporate debtor, creditors and governmental authorities under section 31(1). Pre-approval liabilities and proceedings covered by the plan stand extinguished, so an appeal based on a claim arising before approval does not survive for adjudication. The approved plan therefore brings finality to the covered claims and bars continuation of proceedings within its scope.

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Issues: Whether the appeal survived after approval of the Resolution Plan under the Insolvency and Bankruptcy Code, 2016, and whether pre-approval claims against the corporate debtor stood extinguished.

Analysis: The Resolution Plan had been approved by the National Company Law Tribunal and was held to be in accordance with section 30(2) of the Insolvency and Bankruptcy Code, 2016 and the relevant CIRP Regulations. The approved plan expressly bound the corporate debtor, its creditors and governmental authorities in terms of section 31(1) of the Code. As the appeal related to a claim arising prior to the approval date, and the plan provided for extinguishment of pre-approval liabilities and proceedings, nothing survived for adjudication.

Conclusion: The appeal did not survive after approval of the Resolution Plan and was disposed of.

Ratio Decidendi: Once a Resolution Plan is approved under section 31(1) of the Insolvency and Bankruptcy Code, 2016, it binds all stakeholders and extinguishes pre-approval claims and proceedings covered by the plan.

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