Liquidation completion and secured creditor realisation upheld where statutory priority of costs was followed before dissolution.

Liquidation completion under the insolvency framework justified dissolution where the liquidation report showed full realisation of assets, verification of claims, closure of the liquidation account, and no remaining assets or liabilities for distribution. The tribunal accepted that the secured creditor could realise its security interest after obtaining the liquidator's permission, and that the sale proceeds were properly applied first towards insolvency resolution process cost and liquidation cost before adjustment against secured debt. The liquidation proceedings were accordingly brought to an end, the corporate debtor stood dissolved, and the liquidator was discharged in line with the statutory distribution scheme.

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Issues: (i) Whether the corporate debtor had completed liquidation so as to warrant dissolution under the insolvency framework. (ii) Whether the secured creditor could realise its security interest and the sale proceeds be applied in accordance with the statutory priority scheme.

Issue (i): Whether the corporate debtor had completed liquidation so as to warrant dissolution under the insolvency framework.

Analysis: The liquidation report showed that the assets of the corporate debtor had been fully liquidated, claims were invited and verified, the liquidation account was closed, and no further assets or liabilities remained for distribution. The statutory requirements for completion of liquidation and dissolution were thus satisfied.

Conclusion: Dissolution of the corporate debtor was warranted and ordered with immediate effect.

Issue (ii): Whether the secured creditor could realise its security interest and the sale proceeds be applied in accordance with the statutory priority scheme.

Analysis: The secured creditor elected to realise its security interest, obtained permission from the liquidator, conducted sale of the secured assets, and deposited the insolvency resolution process cost and liquidation cost from the proceeds before adjusting the balance towards its secured debt. The distribution accorded with the statutory waterfall and priority of costs.

Conclusion: The secured creditor's realisation and appropriation of sale proceeds were accepted as consistent with the governing provisions.

Final Conclusion: The liquidation proceedings were brought to an end, the corporate debtor stood dissolved, and the liquidator was discharged after compliance with the statutory distribution framework.

Ratio Decidendi: Where liquidation is completed, assets are realised, costs are satisfied in statutory priority, and no further distributable estate remains, dissolution of the corporate debtor follows under the insolvency code.

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