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    <title>2026 (6) TMI 1236 - ORISSA HIGH COURT</title>
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    <description>Section 32A of the IBC protects a corporate debtor from prosecution for offences committed before commencement of CIRP once a resolution plan is approved and management changes to persons unconnected with the former control. On that basis, prosecution for alleged pre-CIRP environmental violations was treated as unsustainable. The later decriminalisation of offences under Section 15 of the Environment (Protection) Act, 1986 by the Jan Vishwas (Amendment of Provisions) Act, 2023 was also held to support quashing of the pending criminal case, because the alleged contravention had been shifted from a penal to a civil penalty regime. The proceedings were found incapable of being sustained in law.</description>
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