Tuesday, July 1, 2025

Insolvency and Bankruptcy Code 2016-Reply to section 8 notice not necessary

 

Insolvency and Bankruptcy Code 2016-Reply to section 8 notice not necessary

The Insolvency & Bankruptcy Code (IBC) 2016 is a comprehensive code for resolution, rehabilitation and dissolution of the assets of corporate debtors in the face of liability of such corporate debtor, a company incorporate dunder the provisions of Companies Act 2013. The Financial Creditors (FCs) or Operational Creditors (OCs) as the case may be, may prefer petition for seeking initiation of Corporate Insolvency resolution Process (CIRP) against the corporate debtor/s, who, despite the admitted liability, refused or omitted to repay the debt owed to such operational creditors.  We know that the threshold of maintaining the petitions is different in respect of Financial Creditor (FC) and Operational Creditors (OCs). We are presently concerned about Operational Creditor. Section 9 of IBC entails the process of preferring petition by Operational Creditors (OCs) under the code. In case, the liability owed by the corporate debtors are evident and admitted, then, the National Company Law Tribunals (NCLTs) upon admitting such petition, sets in motion, Corporate Insolvency Resolution Process (CIRP). As per the procedure laid down under the code, before initiating section 9 proceedings, operational creditor is mandated to issue a notice u/s 8 of IBC 2016 calling upon the corporate debtor to pay the debt within stipulated period. This is a sine qua non for preferring and maintaining a petition u/s 9 of IBC. After service of notice as indicated above, if a corporate debtors under section 9, sends reply and in the reply the corporate debtors raises dispute, and claims that that the alleged liability is under dispute,  being not payable and the disputes existed or subsisted before receiving the notice u/s 9 of IBC 2016, then, in that event, prima facie, the petition u/s 9 of IBC 2016 may not be maintainable. It is so, since, the liability itself is in dispute and not admitted and hence, admission of the petition in this backdrop shall be unlikely. However, a situation may arise to the effect, that, the reply to the notice raising dispute is not sent by a proposed corporate debtor, though, on the basis of petition and documents filed by the Operational Creditor (OCs), the dispute as regards debts owed allegedly by corporate debtor had suggested existence of dispute. Still, the question arises, whether for want of raising dispute by replying to the notice u/s 8 of IBC 2016 received by corporate debtor, shall inevitably go against the corporate debtor and the petition u/s 9 shall have to be admitted is a moot point. In other words, not sending reply to the section 8 notice shall inevitably lead to acceptance of insolvency petition filed by corporate debtor and initiation of Corporate Insolvency Resolution Process (CIRP). The answer is thus craved for, in this perspective and that is further deliberated hereinafter.

The National Company Law Appellate Tribunal (NCLAT), New Delhi (Principal Bench) had occasion to deal with the issue raised above in a recent judgment captioned as Anil Kumar Seth vs Valplast Technologies Private Limited   Comp. App. (AT) (Ins) No. 1105 of 2024 & I.A. No. 6587 of 2024.

The above appeal was directed by the suspended Directors of corporate debtor company, against the order dated 14.05.2024 by which the National Company Law Tribunal, Allahabad Bench, Prayagraj ('Tribunal') had admitted an application filed by M/s Valplast Technologies Pvt. Ltd. on 02.06.2023, under Section 9 of the Insolvency & Bankruptcy Code, 2016 ('Code'), against M/s Supercast Technologies Pvt. Ltd. ('Corporate Debtor') for the resolution of an amount of Rs. 2,29,48,069.19/- and also appointed an Insolvency Resolution Professional (IRP).

In this appeal, it was alleged by the Suspended Director of the Corporate Debtor, that the issue of pre-existing dispute, raised by the Appellant, had not been decided by the Tribunal in accordance with law and it was alleged that the Tribunal has not looked into various emails/ letters exchanged between the parties which were attached with the reply affidavit only on the ground that the Appellant did not file reply to the demand notice issued under section 8 of the Code. Reliance was placed on M/s Brand Realty Services Ltd. vs. M/s Sir John Bakeries India Pvt. Ltd. in Company Appeal (AT) (Ins.) No. 958 of 2020 decided on 10.03.2022 and para 12 of the said judgment are reproduced as under:

"12. ***Section 8(2) of the Code provides that the corporate debtor shall, within a period of ten days of the receipt of the demand notice or copy of the invoice mentioned in sub- section (1) bring to the notice of the operational creditor- (a) existence of a dispute. Section 9(1) of the Code provides that After the expiry of the period of ten days from the date of delivery of the notice or invoice demanding payment under sub-section (1) of section 8, if the operational creditor does not receive payment from the corporate debtor or notice of the dispute under sub-section (2) of section 8, the operational creditor may file an application before the Adjudicating Authority for initiating a corporate insolvency resolution process. Section 8(2) when read with Section 9(1), it is clear that Section 9(1) enables the Operational Creditor to file Section 9 application if no payment has been received by the Operational Creditor form Corporate Debtor or no notice of the dispute under sub-section (2) of section 8 has been received. The statutory scheme under Section 8 and 9 does not indicate that in an event Reply to Notice is not filed within 10 days by Corporate Debtor or no Reply to Notice under Section 8(1) have been given, the Corporate Debtor is precluded from raising the question of dispute."

The case of the appellant therefore was that the communication between the parties was filed with the memo of appeal and if these communications are taken note of, the indication of pre-existing dispute shall be evident and such a petition is liable to be dismissed at the threshold. Though, the respondent had vociferously submitted that reply to section 8 notice by way of notice of dispute shall have to be sent by corporate debtor, as per the mandate of section 8 of IBC and if that is not done, the issue of dispute raised thereafter and more so after filing of petition u/s 9 of IBC shall be misconceived.

The nclat New Delhi in Anil Kumar Seth (Supra) has thus held as under:

9. We are of the considered opinion that finding of the Learned Tribunal is not acceptable as it is contrary to the well settled law that even if no reply is filed to the notice issued under Section 8 of the Code, the court is obliged to look into the material produced before it by the Corporate Debtor for proving that there was a pre-existing dispute between the parties before the issuance of notice under Section 8 of the Code.

The order passed by NCLAT we therefore, set aside and appeal was allowed and the main petition bearing CP No. 36/ALD/ 2023 was thus restored and remanded back to the NCLT for rendering decision in accordance with law, since, after taking into consideration the emails/ letters exchanged between the parties before 08.05.2023 when the notice under Section 8 was issued, there is no doubt that prima facie dispute existed and sending no reply and notice of dispute to the notice u/s 8 of IBC 2016 shall not, in itself, preclude the corporate debtor from raising pleas of dispute in the course of hearing before NCLT and the same shall have to be decided in accordance with law. It was thus left on the tribunal to decide, afresh, the issue of pre-existing dispute after going through the material on record. It was held that as the matter was decided in the backdrop, that, reply to section 8 IBC notice was not filed, and decision based on that premise itself, is not correct. The NCLAT had accorded liberty to the parties to file additional documents, if necessary.

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Anil K Khaware

Founder & Senior Associate

Sociertylawandjustice.com

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Insolvency and Bankruptcy Code 2016-Reply to section 8 notice not necessary

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