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    <title>2023 (4) TMI 1148 - MADRAS HIGH COURT</title>
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    <description>A post-sanction modification to a scheme of arrangement was refused because it was not shown to benefit debenture holders and appeared to serve mainly the promoters and former management. The sanctioned scheme had not been effectively implemented, and the proposed transfer of litigated properties to a trust was found unlikely to provide any immediate creditor benefit. The post-sanction applications were treated as retained by the High Court, and the earlier refusal to transfer the proceedings was held to have attained finality. The Companies Act, 2013 was held not to require transfer of these scheme-related proceedings to the NCLT, so the modification application and transfer request failed.</description>
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      <description>A post-sanction modification to a scheme of arrangement was refused because it was not shown to benefit debenture holders and appeared to serve mainly the promoters and former management. The sanctioned scheme had not been effectively implemented, and the proposed transfer of litigated properties to a trust was found unlikely to provide any immediate creditor benefit. The post-sanction applications were treated as retained by the High Court, and the earlier refusal to transfer the proceedings was held to have attained finality. The Companies Act, 2013 was held not to require transfer of these scheme-related proceedings to the NCLT, so the modification application and transfer request failed.</description>
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