Extinguished arbitral award claims cannot be revived after resolution plan approval, while court-held security remains the corporate debtor's asset.

An arbitral award constitutes a claim under the Insolvency and Bankruptcy Code, 2016, and an award-holder is a creditor. Where the award-holder does not submit its claim in the corporate debtor's CIRP and the claim is excluded from the approved resolution plan, the claim is extinguished and a pending challenge to the award cannot revive it. Money deposited in court solely as security for a stay of award enforcement remains an asset of the corporate debtor because custody does not transfer ownership to the award-holder. Once the underlying claim is extinguished, the award-holder has no unconditional entitlement to the deposit, which is refundable with accrued interest to the corporate debtor.

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Issues: (i) Whether an arbitral award-holder's claim, not lodged in the corporate debtor's CIRP and not included in the approved resolution plan, survives and permits continuation of the challenge to the award; (ii) Whether the amount deposited in court as security for stay of enforcement of the award is refundable to the corporate debtor after approval of the resolution plan.

Issue (i): Whether an arbitral award-holder's claim, not lodged in the corporate debtor's CIRP and not included in the approved resolution plan, survives and permits continuation of the challenge to the award.

Analysis: An amount awarded under an arbitral award constitutes a claim and the award-holder is a creditor under the Insolvency and Bankruptcy Code, 2016. The approved resolution plan binds creditors, while claims not forming part of that plan stand extinguished. The award-holder did not submit its claim to the resolution professional; consequently, its claim was not incorporated in the approved plan. Continuance of the Section 34 challenge could not revive an extinguished claim.

Conclusion: The claim under the arbitral award stood extinguished upon approval of the resolution plan, and the challenge to the award became academic, in favour of the petitioner.

Issue (ii): Whether the amount deposited in court as security for stay of enforcement of the award is refundable to the corporate debtor after approval of the resolution plan.

Analysis: A court deposit required as a condition for stay secures the award amount pending adjudication and does not transfer ownership of the money to the award-holder. Release remains subject to the court's control and may be conditioned or modified. Such deposited funds remain assets of the corporate debtor, notwithstanding custody by the court. Since the underlying award claim was extinguished, no unconditional right to the secured deposit remained with the award-holder.

Conclusion: The deposited amount, together with accrued interest, is refundable to the petitioner, in favour of the petitioner.

Final Conclusion: Approval of the resolution plan eliminated the unsubmitted award claim and preserved the corporate debtor's entitlement to funds deposited merely as security.

Ratio Decidendi: A claim under an arbitral award that is not submitted and incorporated in an approved resolution plan is extinguished, and money deposited in court solely as security for that award remains an asset of the corporate debtor.

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