CIRP claim finality prevents belated admission where timelines lapse and supporting records fail to prove homebuyer status.

Belated claims in CIRP cannot be reopened after the prescribed filing timeline and approval of the resolution plan, because insolvency resolution is time-bound and must preserve the fresh-slate basis of the plan. The COVID extension did not help where the limitation period had already expired before 15.03.2020, and the approved commercial framework could not be displaced. The claimed status as a homebuyer or financial creditor also failed because the receipt, allotment and buy-back documents were unreliable, the alleged payment was not reflected in the corporate records, and no independent proof of disbursal was produced. The challenge to rejection of the claim therefore failed.

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Issues: (i) whether a claim filed long after the prescribed timeline and after approval of the resolution plan by the committee of creditors could be directed to be admitted; (ii) whether the material produced by the appellant established a genuine claim as a homebuyer/financial creditor.

Issue (i): whether a claim filed long after the prescribed timeline and after approval of the resolution plan by the committee of creditors could be directed to be admitted.

Analysis: The claim was filed after the expiry of the public-announcement timeline and even beyond the extended period contemplated for belated filing. The insolvency process is time-bound, and belated claims cannot be reopened merely because the resolution plan has not yet received approval of the adjudicating authority. The governing principle is that all claims must be lodged and considered within the CIRP framework so that the resolution applicant proceeds on a fresh slate. Delay beyond the prescribed period could not be condoned on the facts, and the COVID extension order did not assist because the limitation period had already expired before 15.03.2020. The commercial wisdom exercised in the approved plan could not be displaced.

Conclusion: The request to admit the belated claim was not maintainable and was rightly rejected.

Issue (ii): whether the material produced by the appellant established a genuine claim as a homebuyer/financial creditor.

Analysis: The alleged receipt, allotment and buy-back documents were found unreliable because the receipt was not reflected in the books of account, lacked ordinary accounting particulars, and no independent proof of disbursal was produced. The records also showed inconsistency in the unit details and reflected the unit in another person's name. The asserted status as a homebuyer was therefore not established on credible material, and the plea of indoor management or restoration under void agreement principles did not assist in the absence of proof of payment and allotment in the corporate records.

Conclusion: The appellant failed to establish a credible subsisting claim against the corporate debtor.

Final Conclusion: The challenge to the rejection of the belated claim failed, and the dismissal of the application was upheld in view of the strict timelines under the insolvency framework and the lack of trustworthy evidence supporting the asserted claim.

Ratio Decidendi: A claim not lodged within the CIRP timelines and not supported by reliable contemporaneous records cannot be admitted after approval of the resolution plan by the committee of creditors, since the insolvency process must preserve finality, certainty, and the fresh-slate basis of resolution.

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