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Issues: Whether the resolution professional could summarily reject the applicants' claims for delay or defects in the claim form without first seeking rectification and placing the matter before the committee of creditors for a decision on admissibility.
Analysis: The claims were received before approval of the resolution plan, and the admitted factual position was that the principal dues were reflected in the corporate debtor's books. The defects in documentation were capable of being cured by calling for the correct papers. The resolution professional's role under the insolvency framework is administrative: he is required to receive and collate claims and maintain an updated list of claims, but he does not possess adjudicatory power to finally reject a claim on his own without placing the complete facts before the committee of creditors. In these circumstances, a summary rejection without giving an opportunity to rectify the mistake was held to be improper.
Conclusion: The claim applications were directed to be reconsidered on merits by the resolution professional and placed before the committee of creditors with observations for a final decision on admissibility, and the connected request for voting rights was also required to be reconsidered. The relief was therefore granted in favour of the applicants, but only by way of fresh consideration rather than direct admission of the claims.
Final Conclusion: The tribunal required a fresh administrative scrutiny of the claims through the insolvency process and did not itself determine the admissibility of the claims.
Ratio Decidendi: A resolution professional cannot finally reject a creditor's claim on his own where defects are curable and the claim has to be collated and placed before the committee of creditors for an informed decision on admissibility.