Liquidation claim cut-off rules bar post-commencement claims unless expressly covered by the regulations.

Claims in liquidation must be submitted and proved with reference to the liquidation commencement date under the Insolvency and Bankruptcy Code, 2016 and the Liquidation Process Regulations. Claims filed after the public-announcement deadline, or claims that arise only after liquidation commences, cannot ordinarily be admitted because Regulation 16 requires proof of debt as on the liquidation commencement date. Regulation 28 is a limited exception for debt payable at a future time, but it does not extend to a claim that did not exist when liquidation began. A later arbitral award did not change that position, so the liquidator was justified in rejecting the claim.

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Issues: Whether a claim arising after the liquidation commencement date, based on a later arbitral award, could be admitted in liquidation proceedings and whether the liquidator was justified in rejecting a claim filed after the last date prescribed in the public announcement.

Analysis: The statutory scheme under the Insolvency and Bankruptcy Code, 2016 and the IBBI (Liquidation Process) Regulations, 2016 requires claims to be submitted and proved with reference to the liquidation commencement date. Regulation 12(2)(a) calls upon stakeholders to submit claims as on that date, Regulation 16(1) requires submission on or before the last date mentioned in the public announcement, and Regulation 16(2) requires proof of debt or dues as on the liquidation commencement date. Regulation 28, dealing with debt payable at a future time, was treated as the only limited exception, and it did not support admission of a claim that itself arose only after liquidation commencement. The later arbitral award did not alter the position because the claim had not existed on the liquidation commencement date.

Conclusion: The liquidator correctly rejected the claim, and the challenge to that rejection failed.

Ratio Decidendi: When the liquidation regulations fix the liquidation commencement date as the cut-off for filing and proving claims, no claim arising thereafter can be entertained in liquidation except within the limited framework expressly provided by the regulations.

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