Ravikumar Gaurishankar Patel Vs Gajesh Labhchand Jain (NCLAT Delhi)
Summary: NCLAT, Principal Bench, New Delhi partly allowed the appeal of Ravikumar Gaurishankar Patel, the successful auction purchaser of Talwalkars Better Value Fitness Ltd., against the NCLT Mumbai Bench-IV order dated 26.02.2026. The Corporate Debtor had entered CIRP on 11.01.2021, was ordered into liquidation on 28.04.2022, and was sold as a going concern through e-auction for Rs. 15 crore. After payment of the consideration, a Sale Certificate was issued on 23.01.2025. The purchaser sought consequential reliefs and concessions to operationalise the company, including restructuring of share capital, SEBI/stock-exchange compliances, removal of historical banking classifications and charges, protection from past liabilities and proceedings, continuation of licences and approvals, and restoration of the company’s status on the MCA/ROC records.
The NCLAT held that Section 60(5)(c) of the IBC gives the Adjudicating Authority broad residuary jurisdiction over questions having a direct nexus with insolvency or liquidation, including incidental and consequential directions necessary to make a going-concern sale commercially effective. Applying the clean-slate principle and precedents concerning revival of corporate debtors, it held that the purchaser could not be compelled to pursue multiple separate proceedings merely for recognition of legal consequences already flowing from the liquidation sale.
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