Connected lease documents and insolvency-linked eviction disputes may be construed together and brought before NCLT.

An allotment letter, licence agreement and lease deed forming one connected arrangement must be read together, and a 99-year lease does not by itself transfer title. On the facts stated, notice at the registered office and on the property satisfied the statutory requirement, no prejudice from the absence of a further hearing was shown, and the termination and eviction action was not invalid on the grounds raised. The text also states that the National Company Law Tribunal's residuary jurisdiction under the Insolvency and Bankruptcy Code, 2016 extends to disputes arising from or in relation to insolvency or liquidation proceedings, so the Tribunal could entertain the challenge while the parties pursued objections there.

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Issues: (i) Whether the allotment letter, licence agreement and lease deed were to be read together and whether termination under the public premises law was invalid for breach of natural justice. (ii) Whether the disputes arising from termination and eviction could be considered by the National Company Law Tribunal in proceedings under the Insolvency and Bankruptcy Code, 2016.

Issue (i): Whether the allotment letter, licence agreement and lease deed were to be read together and whether termination under the public premises law was invalid for breach of natural justice.

Analysis: The allotment letter, licence agreement and lease deed formed a connected contractual framework and had to be read coterminously. The licence terms were not extinguished merely because the lease deed was executed, and the lease itself incorporated the allotment conditions. The material showed that the allotted land was meant for development within a stipulated schedule, yet no development had been carried out. Service of notice at the registered office and on the property satisfied the statutory requirement, and in the admitted factual matrix no prejudice was shown from absence of a further hearing. A lease for 99 years did not transfer title, but only a right to enjoy the property.

Conclusion: The termination and eviction action was not invalid on the grounds urged by the petitioner.

Issue (ii): Whether the disputes arising from termination and eviction could be considered by the National Company Law Tribunal in proceedings under the Insolvency and Bankruptcy Code, 2016.

Analysis: The residuary jurisdiction under Section 60(5)(c) of the Insolvency and Bankruptcy Code, 2016 is wide enough to cover questions of law or fact arising from or in relation to insolvency or liquidation proceedings. The challenge to the termination, and the respondent's application before the Tribunal, both fell within that jurisdictional framework. At the same time, the Court accepted that the petitioner could raise all objections before the Tribunal in the pending proceedings. The statutory scheme also showed that assets not involving transfer of title are outside the liquidation estate, and proceedings by or against the corporate debtor are controlled by the Code.

Conclusion: The National Company Law Tribunal could entertain the dispute in the pending application.

Final Conclusion: The impugned actions were upheld and the writ petition failed, leaving the parties to pursue their contentions before the Tribunal in the insolvency proceedings.

Ratio Decidendi: Contractual documents forming a single allotment-and-lease arrangement may be construed together, and the National Company Law Tribunal's residuary jurisdiction extends to insolvency-related disputes that arise from or are connected with liquidation proceedings, while not permitting adjudication of matters wholly dehors the insolvency process.

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