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    <title>2026 (4) TMI 1673 - NATIONAL COMPANY LAW APPELLATE TRIBUNAL PRINCIPAL BENCH, NEW DELHI</title>
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    <description>A second charge created under a consent decree and implemented through a duly executed deed of charge can be recognised as a valid security interest in liquidation, even where it is subordinate to a prior charge and does not affect the first charge holder&#039;s priority. Non-registration of that charge with the Registrar of Companies under Section 77 of the Companies Act, 2013 does not, by itself, defeat secured creditor status when the charge is otherwise established, including through registration with the Sub-Registrar and supporting documents. The challenge to secured creditor recognition was therefore rejected and the impugned order sustained.</description>
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      <description>A second charge created under a consent decree and implemented through a duly executed deed of charge can be recognised as a valid security interest in liquidation, even where it is subordinate to a prior charge and does not affect the first charge holder&#039;s priority. Non-registration of that charge with the Registrar of Companies under Section 77 of the Companies Act, 2013 does not, by itself, defeat secured creditor status when the charge is otherwise established, including through registration with the Sub-Registrar and supporting documents. The challenge to secured creditor recognition was therefore rejected and the impugned order sustained.</description>
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