Personal Insolvency Resolution Process extension permitted for procedural completion; moratorium outer limit remains fixed under the Code.

Addresses whether adjudicating authorities may extend the Personal Insolvency Resolution Process (PIRP) timeline beyond the moratorium outer limit under Section 101 of the IBC; concludes that the 180 day moratorium outer limit remains fixed for moratorium protection but does not automatically terminate the PIRP or bar the authority from permitting limited extensions of the resolution process where timelines are procedural or directory and substantive justice or stakeholders' interests require; consequence: applications for procedural extension of PIRP were allowed to permit completion and submission of the repayment plan report within the specified extended period.

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Issues: (i) Whether the Appellate Tribunal/NCLT has jurisdiction to extend the Personal Insolvency Resolution Process (PIRP) period beyond the moratorium/outer limit prescribed under Section 101 of the Insolvency and Bankruptcy Code, 2016, and whether the impugned orders rejecting applications for extension of PIRP should be set aside.

Analysis: Relevant statutory and regulatory provisions include Section 101 (moratorium) and Sections 112-115 (report and order on repayment plan) of the Insolvency and Bankruptcy Code, 2016, and Regulation 19 of the IBBI (Insolvency Resolution Process for Personal Guarantors to Corporate Debtors) Regulations, 2019, which prescribes the timeline for filing an approved repayment plan. Section 101 prescribes that the moratorium ceases on expiry of 180 days from admission or on the date an order is passed under Section 114, whichever is earlier; this fixes the outer limit of the moratorium but does not expressly prescribe automatic termination of the PIRP or preclude the adjudicating authority from exercising its statutory discretion in relation to continuation or extension of the resolution process. Precedents of this Tribunal and the ratio in Supreme Court decisions on analogous provisions (concerning mandatory timelines) establish that where timelines in the Code or regulations are procedural or directory and where substantive justice and stakeholders' interests warrant, the adjudicating authority/Tribunal may in appropriate cases permit extension of the resolution process (while distinguishing that extension of the resolution process does not equate to extension of the moratorium beyond the statutory outer limit of 180 days).

Conclusion: Issue (i) decided in favour of the appellant. The appeals are allowed, the impugned common order dated 28.01.2026 is set aside and the applications for extension of the PIRP are allowed; the PIRP period is extended until 15.03.2026 for procedural completion and submission of the report on the repayment plan.

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