Proceedings under Section 340 Cr.P.C. can be initiated only where the Court records a prima facie finding of deliberate falsehood, supported by material indicating commission of offences under Section 195(1)(b) Cr.P.C., and further records an independent satisfaction that prosecution is expedient in the interests of justice. Mere wrong, inadvertent or typographical statements do not constitute "false statements" attracting Sections 193, 199 or 200 IPC. Orders lacking these statutory prerequisites are unsustainable.

 

PRABHAKAR YESHWANT MASRAM & ANR. v. SOU TULA NAMDEORAO JAIPURKAR & ANR.

2026 INSC 724 | Criminal Appeal No.1365 of 2015
Coram: Ujjal Bhuyan & Atul S. Chandurkar, JJ.
Decided on: 21 July 2026.

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A. Criminal Procedure Code, 1973 — Sections 340 & 195(1)(b) — Initiation of prosecution for perjury — Conditions precedent — Mere prima facie finding of "wrong statement" insufficient.

Paras 6, 7, 11, 12, 16, 17

Before directing prosecution under Section 340 Cr.P.C., the Court must record:

(i) prima facie satisfaction that the alleged statement is false and not merely wrong;

(ii) satisfaction that it is expedient in the interests of justice to prosecute.

Absence of either condition vitiates the order directing prosecution.

Held: Order directing prosecution quashed.

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B. Penal Code, 1860 — Sections 193, 199 & 200 — Wrong statement and false statement — Distinction.

Paras 10, 11, 15

A "wrong statement" is not synonymous with a "false statement."

A false statement necessarily imports an element of conscious falsity, knowledge, or intention to deceive for obtaining an undue advantage.

An inadvertent, mistaken or erroneous statement does not by itself constitute offences under Sections 193, 199 or 200 IPC.

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C. Section 340 Cr.P.C. — Expediency in the interest of justice — Mandatory satisfaction.

Paras 7, 12

Recording satisfaction regarding expediency in the interest of justice is a mandatory statutory requirement.

The Court cannot order prosecution merely because an incorrect statement has been noticed.

The impact of the alleged falsehood upon the administration of justice must be evaluated before exercising jurisdiction.

Relied on:

Iqbal Singh Marwah v. Meenakshi Marwah, 2005 INSC 129.

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D. Perjury proceedings — To be initiated sparingly.

Paras 12, 16, 17

Proceedings under Section 340 Cr.P.C. are exceptional.

Courts should not order prosecution for every incorrect pleading.

Only glaring cases involving deliberate falsehood on material issues, supported by strong evidence and where conviction appears reasonably probable, justify prosecution.

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E. Typographical mistakes in pleadings — Bona fide explanation — No criminal prosecution.

Paras 14, 15

Where mistakes in pleadings arose due to typographical errors and an application seeking correction had already been filed with an explanation and apology before initiation of Section 340 proceedings, such errors cannot be treated as deliberate false statements warranting prosecution.

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F. Appellate Court — Cannot improve defective order while deciding appeal.

Para 13

Where the original Court recorded only that "wrong statements" were made, the appellate Court cannot convert such finding into one of "false statements" nor supply the missing statutory satisfaction regarding expediency.

An appellant cannot be placed in a worse position merely because he preferred an appeal.

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G. Section 340 Cr.P.C. — Proceedings ordinarily after conclusion of main case.

Para 17

Ordinarily proceedings under Section 340 Cr.P.C. should await disposal of the substantive proceedings.

Premature invocation of Section 340 often delays adjudication and should be discouraged.

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CASE FACTS

Paras 1–5

• Plaintiffs filed a civil suit seeking injunction regarding property rights.
• Trial Court granted temporary injunction.
• Defendant preferred Miscellaneous Civil Appeal.
• Plaintiffs alleged that incorrect statements were made in the appeal memorandum and stay application.
• High Court declined contempt proceedings but granted liberty to invoke Section 340 Cr.P.C.
• Appellate Court directed filing of criminal complaint under Sections 193, 199 and 200 IPC against the defendant and his advocate.
• High Court affirmed the order.
• Supreme Court considered whether such prosecution was legally sustainable.

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LAW ANALYSIS

I. Scope of Section 340 Cr.P.C.

Paras 6–12

The Supreme Court reiterated that Section 340 is not meant to prosecute every inaccurate statement made before Court.

Before initiating prosecution, the Court must independently examine:

• existence of a prima facie offence;
• whether the statement is actually false;
• whether prosecution is expedient in the interest of justice.

Both requirements are mandatory.

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II. Difference between "Wrong" and "False"

Paras 11 & 15

The judgment draws an important jurisprudential distinction.

A wrong statement may result from:

• mistake,
• negligence,
• misunderstanding,
• typographical error.

A false statement involves:

• knowledge of falsity,
• deliberate deception,
• intention to mislead the Court.

Only the latter attracts Sections 193, 199 and 200 IPC.

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III. Typographical errors

Paras 14–15

The defendant had sought correction of the typing mistakes much before Section 340 proceedings.

This conduct was inconsistent with any intention to deceive.

Consequently, no prima facie offence was made out.

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IV. Role of Appellate Court

Para 13

The High Court exceeded appellate jurisdiction by:

• substituting "false statement" for "wrong statement";
• supplying the missing finding regarding expediency.

Such improvement of the impugned order is impermissible.

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RATIO DECIDENDI

Proceedings under Section 340 Cr.P.C. can be initiated only where the Court records a prima facie finding of deliberate falsehood, supported by material indicating commission of offences under Section 195(1)(b) Cr.P.C., and further records an independent satisfaction that prosecution is expedient in the interests of justice. Mere wrong, inadvertent or typographical statements do not constitute "false statements" attracting Sections 193, 199 or 200 IPC. Orders lacking these statutory prerequisites are unsustainable.

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IMPORTANT PRINCIPLES LAID DOWN

1. Wrong statement ≠ False statement.
2. Deliberate intention to deceive is essential.
3. Expediency in the interest of justice is mandatory.
4. Section 340 is an exceptional jurisdiction.
5. Perjury prosecution should not become a tool to delay civil litigation.
6. Appellate Court cannot cure defects in the original order by supplying new findings.
7. Bona fide typographical errors do not amount to criminal perjury.

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FINAL DECISION

Para 18

• Criminal Appeal Allowed.
• Orders of the Additional District Judge and the High Court set aside.
• Application under Section 340 Cr.P.C. dismissed.
• No prosecution against the defendant or his advocate

A landlord who establishes a genuine and bona fide requirement under the Rent Act is entitled to eviction, and the Court must ordinarily respect the landlord's choice of the premises. The existence of another property does not by itself negate bona fide requirement. Furthermore, the High Court, while exercising revisional jurisdiction under Section 115 CPC, cannot re-appreciate evidence or overturn concurrent findings of fact unless such findings are perverse, illegal, or suffer from jurisdictional infirmity.

 

MADAN MOHAN (Dead) through LRs v. THAKAR DASS (Dead) through LRs

2026 INSC 730 | Civil Appeal arising out of SLP (C) No.12435 of 2019
Coram: Sanjay Karol & Augustine George Masih, JJ.
Decided on: 21 July 2026

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HEAD NOTES (AIR STYLE)

A. East Punjab Urban Rent Restriction Act, 1949 — Section 13 — Bona fide requirement — Death of original landlord during pendency — Requirement of family member survives.

Paras: 2, 3.3, 9, 11

Where eviction was sought on the ground of bona fide requirement of the landlady as well as her son, the death of the landlady during pendency of proceedings does not extinguish the cause of action, since the son's independent requirement continued to subsist. The eviction petition survives through the legal representatives.

Held: Eviction rightly granted.

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B. Rent Control — Bona fide requirement — Meaning and scope — Genuine need distinguished from mere desire.

Paras: 6, 6.1, 7

"Bona fide requirement" denotes a real, honest and genuine need and not a fanciful or pretended desire. Courts must objectively assess the sincerity of the landlord's need by placing themselves in the position of the landlord. Once the need is proved, the landlord's choice of the premises cannot ordinarily be substituted by judicial opinion.

Relied on:

• Shiv Sarup Gupta v. Mahesh Chand Gupta, (1999) 6 SCC 222.
• Baldev Singh Bajwa v. Monish Saini, (2005) 12 SCC 778.

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C. Alternative accommodation — Landlord's choice — Court cannot compel use of another premises.

Paras: 9

Merely because another shop exists does not disentitle the landlord from seeking eviction where the alleged alternative premises was being used as a store or for waste material and concurrent findings accepted such explanation. The landlord is the best judge of the suitability of his premises.

Held: High Court erred in substituting its own assessment.

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D. Revisional jurisdiction — Section 115 CPC — Concurrent findings of fact — High Court cannot re-appreciate evidence.

Paras: 9, 10, 10.1, 10.2, 10.3

The revisional jurisdiction under Section 115 CPC is supervisory and not appellate. The High Court cannot reassess evidence or upset concurrent findings merely because another view is possible. Interference is justified only where findings are perverse, illegal or suffer from jurisdictional error.

Relied on:

• Masjid Kacha Tank v. Tuffail Mohammed, 1991 Supp (2) SCC 270.
• Hindustan Petroleum Corpn. Ltd. v. Dilbahar Singh, (2014) 9 SCC 78.
• Ambadas Khanduji Shinde v. Ashok Sadashiv Mamurkar, (2017) 14 SCC 132.

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E. Rent legislation — Object — Balance between tenant's protection and landlord's rights.

Paras: 5, 7

Rent control statutes are welfare legislations intended to protect tenants from arbitrary eviction while simultaneously preserving the genuine rights of landlords. The doctrine of bona fide requirement is the statutory mechanism through which this balance is maintained.

Relied on:
Ram Krishan Grover v. Union of India, (2020) 12 SCC 506.

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CASE FACTS

Paras: 2–4

• The landlady instituted eviction proceedings under Section 13 of the East Punjab Urban Rent Restriction Act.
• Eviction was sought on two grounds:
  1. Non-payment of rent.
  2. Bona fide personal requirement of herself and her son.
• The tenant tendered arrears during the proceedings; consequently, the dispute substantially survived only on the ground of bona fide requirement.
• The Rent Controller and the Appellate Authority concurrently ordered eviction.
• The High Court reversed the concurrent findings on the ground that the landlady had concealed the availability of another shop and therefore had not approached the Court with clean hands.
• The landlords appealed before the Supreme Court.

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LAW ANALYSIS

(i) Bona fide requirement

Paras: 6–9

The Court reiterated that:

• "Requirement" means a genuine necessity and not a mere wish.
• Courts should objectively evaluate whether the need is natural and honest.
• Once the requirement is established, the landlord's preference regarding which premises should be used deserves judicial respect.

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(ii) Alternative accommodation

Para: 9

Availability of another premises does not automatically defeat the claim of bona fide requirement.

The Court observed that:

• the alleged third shop was concurrently found to be used as storage;
• the High Court wrongly re-appreciated factual evidence;
• the landlord cannot be compelled to use another premises merely because it exists.

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(iii) Revisional jurisdiction

Paras: 10–10.3

The Supreme Court reaffirmed that:

• revision is not a first appeal;
• concurrent findings cannot be disturbed merely because another interpretation is possible;
• interference is confined to jurisdictional error, perversity or material illegality.

The High Court exceeded the limits of Section 115 CPC by reassessing factual findings.

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RATIO DECIDENDI

A landlord who establishes a genuine and bona fide requirement under the Rent Act is entitled to eviction, and the Court must ordinarily respect the landlord's choice of the premises. The existence of another property does not by itself negate bona fide requirement. Furthermore, the High Court, while exercising revisional jurisdiction under Section 115 CPC, cannot re-appreciate evidence or overturn concurrent findings of fact unless such findings are perverse, illegal, or suffer from jurisdictional infirmity.

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FINAL DECISION

Paras: 11

• Appeal Allowed.
• High Court judgment set aside.
• Orders of the Rent Controller and Appellate Authority restored.
• Tenant directed to deliver vacant possession within two months.
• No order as to costs. 

Appointment to teaching or non-teaching posts in aided minority madrasahs made without strict compliance with the prescribed statutory recruitment procedure—including sanctioned vacancy, public advertisement, competent selection process and approval requirements—is void in law and confers no enforceable right to approval, salary or regularisation. The Supreme Court's power under Article 142 cannot be exercised to legitimise such illegal appointments.

  Najma Khatun & Ors. v. State of West Bengal & Ors., 2026 INSC 691

The Supreme Court held that teachers and non-teaching staff appointed in aided minority madrasahs during the interregnum (after the High Court struck down the Madrasah Service Commission Act, 2008, but before and after the Act was ultimately upheld by the Supreme Court) do not acquire any vested or enforceable right to service benefits merely because they were appointed during that period. Their appointments are valid only if they were made strictly in accordance with the governing recruitment rules and statutory notifications.

The Court further laid down the following principles:

1. Verification of appointments is mandatory. The Committee constituted by the Supreme Court in Snehasis Giri was competent to examine whether each appointment satisfied the prescribed legal requirements, notwithstanding the observations in Sk. Mohd. Rafique.

2. Compliance with recruitment procedure is mandatory, not directory. Requirements such as:

   • existence of a sanctioned vacancy,
   • open advertisement in State-level newspapers,
   • constitution of a valid Selection Committee,
   • communication to the District Inspector of Schools and other competent authorities, and
   • appointment by a duly competent Managing Committee,

   are essential conditions. Breach of these requirements renders the appointment illegal.

3. An illegal appointment creates no enforceable legal right. Persons appointed contrary to the statutory procedure cannot invoke Articles 14, 16, 21, or 32 to seek approval of service, salary, or regularisation.
4. Judicial review over the Committee's findings is limited. The Court will interfere only where the findings are shown to be manifestly perverse or arbitrary. It will not reappreciate disputed questions of fact in every individual case.
5. Article 142 cannot be used to validate illegal appointments. The power to do complete justice cannot override mandatory statutory recruitment requirements or protect appointments made in violation of law, particularly where public employment and educational standards are involved.

Ratio

Appointment to teaching or non-teaching posts in aided minority madrasahs made without strict compliance with the prescribed statutory recruitment procedure—including sanctioned vacancy, public advertisement, competent selection process and approval requirements—is void in law and confers no enforceable right to approval, salary or regularisation. The Supreme Court's power under Article 142 cannot be exercised to legitimise such illegal appointments.

Whether a plaint can be rejected under Order VII Rule 11 CPC merely because the defendant pleads that the suit is barred by res judicata? - No

 Pandurangan v. T. Jayarama Chettiar & Anr.

2025 INSC 825 : Civil Appeal No. 7743 of 2025
(Decision dated 14 July 2025)

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HEAD NOTES

A. Civil Procedure Code, 1908 — Order VII Rule 11(d) — Rejection of plaint — Res judicata — Scope.

Paras 3–12

An application under Order VII Rule 11(d) can be decided only on the basis of the averments contained in the plaint. The defence raised by the defendant, the pleadings in the earlier suit, judgments, or external materials cannot be examined at that stage.

Where determination of res judicata requires examination of previous pleadings, issues, judgment and surrounding circumstances, the plaint cannot be rejected under Order VII Rule 11.

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B. Res judicata — Mixed question of law and fact — Trial necessary.

Paras 8–12

The plea of res judicata ordinarily involves examination of—

• identity of parties;
• identity of issues;
• final adjudication;
• competence of previous Court;
• pleadings and findings in earlier proceedings.

Since these matters require evidence and judicial examination, they cannot ordinarily be decided while considering an application under Order VII Rule 11 CPC.

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C. Ex parte decree — Allegation of fraud and collusion.

Paras 6–12

Where the plaint specifically alleges—

• fraud,
• collusion,
• lack of territorial jurisdiction,
• decree not binding upon plaintiff,
• bona fide purchase,

the Court is required to examine these questions during trial.

Such disputed questions cannot be summarily concluded while deciding rejection of plaint.

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D. Previous decree — Not automatically res judicata against subsequent purchaser.

Paras 4–6

A subsequent purchaser, who was not a party to the previous proceedings, is entitled to contend that—

• previous decree is collusive;
• decree is fraudulent;
• decree is void;
• decree is not binding upon him.

Whether such contention succeeds is a matter of evidence and trial.

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E. Order VII Rule 11 — Court cannot adjudicate disputed facts.

Paras 10–12

While deciding rejection of plaint, the Court cannot decide—

• genuineness of fraud;
• bona fide purchase;
• validity of earlier decree;
• territorial jurisdiction of earlier Court;
• applicability of Section 52 Transfer of Property Act.

These are matters for trial.

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FACTS OF THE CASE

Paras 3–7

• Plaintiff purchased the suit property in 1998.
• Vendor had earlier purchased the property in 1991.
• Defendant had already obtained an ex parte partition decree in 1997.
• Plaintiff claimed he had no notice of the earlier litigation.
• Plaintiff alleged fraud, collusion and lack of territorial jurisdiction in obtaining the earlier decree.
• Plaintiff instituted a suit for declaration that the earlier decree was not binding.
• Defendant sought rejection of plaint under Order VII Rule 11 CPC on the ground of res judicata.
• Trial Court allowed the application.
• High Court affirmed.
• Plaintiff appealed before the Supreme Court.

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QUESTIONS OF LAW

Paras 3 & 8

Whether a plaint can be rejected under Order VII Rule 11 CPC merely because the defendant pleads that the suit is barred by res judicata?

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SUPREME COURT'S ANALYSIS

I. Scope of Order VII Rule 11

Paras 8–10

The Court reiterated that only the plaint can be looked into.

No defence can be considered.

No evidence can be appreciated.

No previous records can be examined.

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II. Nature of Res Judicata

Paras 8–10

Res judicata is not merely a legal plea.

It requires examination of

• previous pleadings,
• issues,
• findings,
• identity of parties,
• identity of title.

Hence it ordinarily becomes a mixed question of law and fact.

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III. Allegations of Fraud

Paras 6–12

The plaintiff specifically pleaded—

• collusion,
• fraud,
• want of jurisdiction,
• suppression,
• decree not binding.

These allegations require evidence.

Therefore rejection of plaint was legally unsustainable.

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IV. Error of Trial Court

Paras 10–11

The Trial Court virtually decided the merits of the fraud allegation without recording evidence.

Such an exercise falls outside the jurisdiction under Order VII Rule 11 CPC.

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V. High Court's Error

Paras 11–12

The High Court failed to notice that the Trial Court had entered into disputed factual questions.

It wrongly affirmed rejection of plaint.

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RATIO DECIDENDI

Paras 8–12

A plaint cannot be rejected under Order VII Rule 11(d) CPC on the ground of res judicata where adjudication of such plea requires examination of disputed facts, previous pleadings, earlier judgment, allegations of fraud, collusion, or other evidence beyond the plaint.

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PRINCIPLES LAID DOWN

1. Order VII Rule 11 is confined to the plaint alone.
2. Defendant's defence cannot be looked into.
3. Res judicata generally requires trial.
4. Fraud and collusion cannot be decided summarily.
5. Previous ex parte decree does not automatically bar a subsequent suit.
6. Mixed questions of law and fact cannot be determined under Order VII Rule 11.

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CASES RELIED UPON

Paras 8–10

1. Srihari Hanumandas Totala v. Hemant Vithal Kamat, (2021) 9 SCC 99.
   • Res judicata generally lies beyond the scope of Order VII Rule 11.
2. V. Rajeshwari v. T.C. Saravanabava, (2004) 1 SCC 551.
   • Similarity of causes of action requires trial and examination of previous records.
3. Keshav Sood v. Kirti Pradeep Sood, Civil Appeal No. 5841 of 2023.
   • Defence and previous judgments cannot be considered under Order VII Rule 11.

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FINAL DECISION

Paras 13–15

• Appeal Allowed.
• Orders of Trial Court and High Court Set Aside.
• Suit Restored to file.
• Expeditious disposal directed.
• Supreme Court expressly kept all issues including res judicata open for final adjudication after trial, without expressing any opinion on the merits. 

Once a Resolution Plan is approved under Section 31 of the Insolvency and Bankruptcy Code, all claims stand frozen in the manner provided therein and every claim not incorporated in the Plan stands extinguished. Operational creditors whose disputed claims had not crystallised into quantified liabilities by the effective date of the Resolution Plan cannot continue civil suits or arbitration proceedings for recovery of such pre-CIRP dues. The approved Resolution Plan must be read as a whole, giving full effect to the "clean slate" doctrine, thereby enabling the Successful Resolution Applicant to take over the Corporate Debtor free from past liabilities not preserved by the Plan.

 

2026 INSC 717

M/s Tata Steel Ltd. v. Varsha & Anr.

HEAD NOTES 

A. Insolvency and Bankruptcy Code, 2016 — Sections 30 & 31 — Approved Resolution Plan — Binding effect.

Held, once a Resolution Plan is approved under Section 31, it is final and binding upon the Corporate Debtor, Successful Resolution Applicant, creditors and all stakeholders. Claims not provided for in the Resolution Plan stand extinguished and cannot thereafter be enforced through civil suits, arbitration or other proceedings.

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B. Operational Creditors — Pending Civil Suits and Arbitration — Effect of approval of Resolution Plan.

Held, civil suits and arbitral proceedings relating to pre-CIRP operational debts, which had not crystallised into quantified claims by the effective date of the Resolution Plan, automatically stand withdrawn, abated, extinguished or waived in accordance with the approved Resolution Plan.

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C. Insolvency Resolution — "Clean Slate" Doctrine.

Held, the Successful Resolution Applicant must commence business on a "clean slate". Permitting unresolved or contingent claims to survive after approval of the Resolution Plan would defeat the very object of the Insolvency and Bankruptcy Code and create commercial uncertainty.

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D. Operational Creditors — Notional admission of claim at ₹1 — Effect.

Held, where disputed operational claims were finally verified and admitted only at a quantified value of ₹1 in the Final List of Creditors, the creditors cannot subsequently pursue the original disputed amounts through independent proceedings after approval of the Resolution Plan.

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E. Resolution Professional — Final List of Creditors — Finality.

Held, once the Final List of Creditors attains finality and remains unchallenged, the treatment of claims under the approved Resolution Plan becomes binding. Operational creditors cannot subsequently reopen the categorisation or valuation of their claims indirectly through civil or arbitral proceedings.

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F. Commercial Wisdom of Committee of Creditors.

Held, allocation and treatment of operational creditors under a Resolution Plan form part of the commercial wisdom of the Committee of Creditors, which is ordinarily non-justiciable except on the limited grounds recognised under the Insolvency and Bankruptcy Code.

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G. Resolution Plan — Interpretation.

Held, a Resolution Plan must be read as an integrated commercial document. Individual clauses cannot be interpreted in isolation to preserve claims expressly extinguished elsewhere in the Plan. Harmonious construction must prevail.

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H. MSMEs and Small Operational Creditors — Legislative Concern.

Held, although the existing statutory framework places operational creditors, including MSMEs and local bodies, at a significant disadvantage in insolvency distribution, any modification of the repayment mechanism lies within the legislative domain. The Court recommended consideration of the issue by the Law Commission and Legislature.

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Analysis of Facts

Bhushan Steel Limited entered Corporate Insolvency Resolution Process (CIRP).

Prior to commencement of CIRP, one operational creditor had instituted a civil recovery suit, while another had initiated multiple arbitration proceedings against the Corporate Debtor.

Both creditors submitted their claims before the Resolution Professional during CIRP. Since their claims were under adjudication elsewhere, they were admitted in the Final List of Creditors at a quantified value of ₹1 each.

The Committee of Creditors approved Tata Steel's Resolution Plan, which was subsequently sanctioned by the NCLT.

Despite approval of the Resolution Plan, the operational creditors continued their civil suit and arbitration proceedings. The High Courts permitted continuation of those proceedings.

The Successful Resolution Applicant challenged those orders before the Supreme Court.

The Supreme Court held that the approved Resolution Plan extinguished all unresolved pre-CIRP claims except to the extent expressly recognised therein. Since the operational creditors' claims stood finally quantified at ₹1 each and the Resolution Plan had attained finality, continuation of the pending civil and arbitral proceedings was impermissible. The appeals were accordingly allowed and the proceedings dismissed.

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Analysis of Law

The Supreme Court laid down the following principles:

1. Approval of a Resolution Plan under Section 31 freezes all claims against the Corporate Debtor.

2. Claims not incorporated in the Resolution Plan stand extinguished.

3. The "clean slate" principle protects the Successful Resolution Applicant from unforeseen liabilities after takeover.

4. Operational creditors whose disputed claims are finally admitted only at a quantified value of ₹1 cannot subsequently enforce larger disputed claims.

5. The Final List of Creditors, if unchallenged, attains finality and binds all stakeholders.

6. The commercial wisdom of the Committee of Creditors regarding treatment of operational creditors is ordinarily immune from judicial interference.

7. A Resolution Plan must be interpreted harmoniously as one integrated commercial document.

8. Civil suits and arbitration proceedings relating to pre-resolution operational claims which remain uncrystallised at the effective date stand withdrawn, abated or extinguished in accordance with the approved Resolution Plan.

9. While recognising hardships faced by MSMEs and small operational creditors under the present insolvency regime, any alteration of the statutory repayment framework is a matter for legislative intervention rather than judicial modification.

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Ratio Decidendi

Once a Resolution Plan is approved under Section 31 of the Insolvency and Bankruptcy Code, all claims stand frozen in the manner provided therein and every claim not incorporated in the Plan stands extinguished. Operational creditors whose disputed claims had not crystallised into quantified liabilities by the effective date of the Resolution Plan cannot continue civil suits or arbitration proceedings for recovery of such pre-CIRP dues. The approved Resolution Plan must be read as a whole, giving full effect to the "clean slate" doctrine, thereby enabling the Successful Resolution Applicant to take over the Corporate Debtor free from past liabilities not preserved by the Plan.