Clean slate principle bars belated provident fund claims after resolution plan approval in insolvency proceedings.

Belated provident fund claims filed after approval of the resolution plan cannot be admitted in the corporate insolvency resolution process when the claim was not submitted within the prescribed timeline and was raised only after collation of claims by the Committee of Creditors. The tribunal applied the clean slate principle, holding that a successful resolution applicant cannot be exposed to fresh or undecided liabilities after plan approval, even where the claim concerns statutory dues. As the original claim had already been accounted for in the approved plan and the additional claim was filed much later without timely disclosure, the resolution professional was justified in rejecting it as time-barred. The rejection was upheld.

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Issues: Whether a belated additional claim for provident fund dues, filed after approval of the resolution plan by the Committee of Creditors, could be directed to be admitted in the corporate insolvency resolution process.

Analysis: The appellate tribunal held that the insolvency framework requires claims to be submitted within the prescribed timeline after public announcement and to be collated before the resolution plan is considered by the Committee of Creditors. The appellant's original claim had already been admitted and accounted for in the approved plan, but the additional claim was filed much later, after the plan had been approved by the Committee of Creditors. Relying on the settled position that insolvency resolution must proceed on a clean slate and that the successful resolution applicant cannot be confronted with fresh or undecided claims after approval of the plan, the tribunal held that such belated claims cannot be reopened merely because they relate to statutory dues. The tribunal further held that the resolution professional was justified in rejecting the claim as time-barred and unsupported by timely disclosure.

Conclusion: The belated additional claim could not be admitted, and the rejection of the claim was upheld.

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