Commercial wisdom in insolvency permits rejection of resolution plans and closure of the process under an express bid framework.

Where a bid framework expressly reserved power to accept, reject or annul the process, the Committee of Creditors could terminate the resolution process even without completing the challenge mechanism. The framework's negotiation and challenge features did not create an absolute bar on closure when the plans were found commercially unviable and below liquidation value. An unsuccessful resolution applicant had no vested right to insist on acceptance of its plan or continuation of the process, and judicial review remained confined to narrow statutory grounds. On that basis, rejection of the plans and annulment of the process were upheld, and the challenge to reissue of the bidding process was not maintained.

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Issues: (i) Whether the Committee of Creditors could reject the resolution plans and annul the resolution process without completing the challenge mechanism contemplated in the bid framework and the CIRP Regulations; (ii) Whether an unsuccessful resolution applicant could maintain a challenge to the rejection of its plan and the reissue of the bidding process.

Issue (i): Whether the Committee of Creditors could reject the resolution plans and annul the resolution process without completing the challenge mechanism contemplated in the bid framework and the CIRP Regulations.

Analysis: The bid framework contemplated negotiations and a challenge mechanism, but it also reserved an express right to the Resolution Professional and the Committee of Creditors to accept, reject, or annul the bid process and any or all resolution plans without assigning reasons. The record showed repeated participation by the resolution applicants, multiple rounds of revision of plans, and later deliberation by the Committee of Creditors, which recorded financial non-viability and values below liquidation value as the basis for rejection. In that setting, the challenge mechanism did not operate as an absolute embargo on the power to terminate the process, and the commercial decision of the Committee of Creditors remained within its domain.

Conclusion: The rejection of the plans and annulment of the resolution process were held to be permissible and not contrary to the governing framework.

Issue (ii): Whether an unsuccessful resolution applicant could maintain a challenge to the rejection of its plan and the reissue of the bidding process.

Analysis: The resolution applicant had no vested right to insist that its plan be accepted or that the process be continued in a particular manner once the Committee of Creditors, acting within its commercial wisdom, decided otherwise. Judicial review over such decisions is narrow and is confined to limited statutory grounds. The applicant's participation in the process and opportunity to revise its bid also negatived the complaint of denial of participation or procedural unfairness of the kind that would justify interference.

Conclusion: The challenge by the unsuccessful resolution applicant was held not maintainable on merits, and no interference was warranted.

Final Conclusion: The appellate tribunal affirmed the rejection of the resolution plans and upheld the closure of the resolution process, resulting in dismissal of the appeal.

Ratio Decidendi: Where the bid framework expressly reserves a power to reject or annul the process, the Committee of Creditors may do so in the exercise of its commercial wisdom, and such a decision is subject only to limited judicial review on the narrow statutory grounds governing resolution-plan approval.

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