Claim timeliness under insolvency rules: statutory seven day cutoff upheld, belated claim filed four days before CoC barred.

Regulation 13(1B) permits verification and categorisation only for claims received after the Regulation 12 period up to seven days before the CoC meeting, and Regulation 13(1C) requires intimation and placement of acceptable late claims and, if necessary, seeking condonation. Applying these rules and the proviso to Regulation 6A on public announcement as notice, the RP's refusal to admit a claim filed four days before the CoC meeting was consistent with the statutory cutoff and the policy of finality in the insolvency process; the earlier order rejecting the belated claim was therefore upheld.

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Issues: Whether the Resolution Professional committed any irregularity in rejecting the appellant's belated claim submitted four days before the Committee of Creditors meeting, in light of Regulation 13(1B) and 13(1C) of the IBBI (Insolvency Resolution Process for Corporate Persons) Regulations, 2016.

Analysis: The appeal arises from dismissal of IA seeking admission of a Rs. 10,30,528 claim filed on 15.03.2024, four days before the CoC meeting fixed for 19.03.2024. Regulation 13(1B) permits verification and categorisation of claims received after the period under regulation 12 only up to seven days before the CoC meeting for voting on the resolution plan; Regulation 13(1C) prescribes intimation and placing acceptable claims before the committee and, where applicable, before the Adjudicating Authority for condonation. The Tribunal examined whether earlier decisions relied upon by the appellant applied, noting those precedents concerned claims filed before the insertion of Regulations 13(1B) and 13(1C). The Tribunal also considered Regulation 6A and the proviso deeming public announcement to constitute communication where individual notice cannot be sent. The reasoning emphasises the policy imperative of finality and timeliness in CIRP: permitting belated claims after the seven-day cutoff risks reopening the resolution process, undermining certainty and the fresh slate principle as recognised by higher courts.

Conclusion: The Resolution Professional did not commit any irregularity in rejecting the appellant's belated claim; the Adjudicating Authority's order is upheld and the appeal is dismissed against the appellant.

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