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    <title>2026 (5) TMI 651 - NATIONAL COMPANY LAW APPELLATE TRIBUNAL PRINCIPAL BENCH, NEW DELHI</title>
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    <description>A Section 94 insolvency application filed after an auction sale had already been concluded and confirmed could not be used to unsettle completed SARFAESI recovery measures or divest the auction purchaser of crystallised rights, because the moratorium under Section 96 operated prospectively. The Tribunal also treated the belated filing as lacking bona fides, since the sequence of events indicated an attempt to obstruct recovery rather than pursue genuine insolvency resolution. On that basis, the rejection of the Section 94 applications was upheld and the appeals failed.</description>
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      <description>A Section 94 insolvency application filed after an auction sale had already been concluded and confirmed could not be used to unsettle completed SARFAESI recovery measures or divest the auction purchaser of crystallised rights, because the moratorium under Section 96 operated prospectively. The Tribunal also treated the belated filing as lacking bona fides, since the sequence of events indicated an attempt to obstruct recovery rather than pursue genuine insolvency resolution. On that basis, the rejection of the Section 94 applications was upheld and the appeals failed.</description>
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