Landmark IBC Judgments for the Limited Insolvency Examination
Twelve Supreme Court rulings that settle admission, plan approval and what survives a plan.
IBBI's syllabus for the Limited Insolvency Examination lists 72 judgments in Annexure 1. Only five one-mark questions are asked on them directly, but the principles they settled decide facts in almost every case study: whether an application must be admitted, what the committee of creditors (CoC) may decide on its own, and what survives an approved resolution plan.
The table below covers the Supreme Court rulings that do the most work in exam scenarios. The exam tests the law as it stood on 4 February 2025, so the last column flags where the IBC (Amendment) Act, 2026, in force from 26 May 2026, has since codified or changed the position.
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The Judgments That Decide Case-Study Facts
Dates are the dates of judgment. Each case is on IBBI's Annexure 1 list.
Innoventive Industries v. ICICI Bank
Decided
31 Aug 2017
What it settled
Under section 7, once the NCLT is satisfied a default has occurred, the application must be admitted unless it is incomplete.
After the 2026 Act
Section 7(5) now says the NCLT shall admit, within 14 days
Mobilox Innovations v. Kirusa Software
Decided
21 Sep 2017
What it settled
A section 9 application fails if a pre-existing dispute exists: a plausible contention needing investigation, not a patently feeble argument.
After the 2026 Act
Unchanged
ArcelorMittal India v. Satish Kumar Gupta
Decided
4 Oct 2018
What it settled
A resolution applicant caught by section 29A(c) must pay off the related NPA dues before submitting its plan to become eligible.
After the 2026 Act
Unchanged
Swiss Ribbons v. Union of India
Decided
25 Jan 2019
What it settled
Upheld the Code: the financial/operational creditor distinction, section 12A, section 29A and section 53 all valid.
After the 2026 Act
Section 12A rewritten
K. Sashidhar v. Indian Overseas Bank
Decided
5 Feb 2019
What it settled
The commercial wisdom of financial creditors in voting on a plan is non-justiciable.
After the 2026 Act
CoC must now record reasons for approving a plan
CoC of Essar Steel v. Satish Kumar Gupta
Decided
15 Nov 2019
What it settled
CoC decides distribution; NCLT review is limited; 330 days is the ordinary outer limit; no undecided claims survive the plan.
After the 2026 Act
Dissenting financial creditor minimum changed
Ghanashyam Mishra v. Edelweiss ARC
Decided
13 Apr 2021
What it settled
Claims not in an approved plan, including Government dues, stand extinguished; the 2019 amendment to section 31 is clarificatory.
After the 2026 Act
Codified in new section 31(6)
Lalit Kumar Jain v. Union of India
Decided
21 May 2021
What it settled
The 15 November 2019 notification on personal guarantors is valid; plan approval does not discharge a personal guarantor.
After the 2026 Act
Codified in section 31(6), Explanation I
Vidarbha Industries v. Axis Bank
Decided
12 Jul 2022
What it settled
Section 7(5)(a) read as discretionary; NCLT could keep admission in abeyance on the facts.
After the 2026 Act
Overtaken: admission is now mandatory when the conditions are met
State Tax Officer v. Rainbow Papers
Decided
6 Sep 2022
What it settled
The State, with a statutory charge under the Gujarat VAT Act, was a secured creditor; a plan ignoring its dues was set aside.
After the 2026 Act
Section 3(31) now excludes security interest created merely by operation of law
M. Suresh Kumar Reddy v. Canara Bank
Decided
11 May 2023
What it settled
Vidarbha confined to its facts; Innoventive still holds good.
After the 2026 Act
Consistent with new section 7(5)
Dilip B. Jiwrajka v. Union of India
Decided
9 Nov 2023
What it settled
Sections 95-100 valid; the resolution professional's role is facilitative and no adjudication happens before section 100.
After the 2026 Act
Section 96 interim moratorium no longer applies to personal guarantor applications
| Case | Decided | What it settled | After the 2026 Act |
|---|---|---|---|
| Innoventive Industries v. ICICI Bank | 31 Aug 2017 | Under section 7, once the NCLT is satisfied a default has occurred, the application must be admitted unless it is incomplete. | Section 7(5) now says the NCLT shall admit, within 14 days |
| Mobilox Innovations v. Kirusa Software | 21 Sep 2017 | A section 9 application fails if a pre-existing dispute exists: a plausible contention needing investigation, not a patently feeble argument. | Unchanged |
| ArcelorMittal India v. Satish Kumar Gupta | 4 Oct 2018 | A resolution applicant caught by section 29A(c) must pay off the related NPA dues before submitting its plan to become eligible. | Unchanged |
| Swiss Ribbons v. Union of India | 25 Jan 2019 | Upheld the Code: the financial/operational creditor distinction, section 12A, section 29A and section 53 all valid. | Section 12A rewritten |
| K. Sashidhar v. Indian Overseas Bank | 5 Feb 2019 | The commercial wisdom of financial creditors in voting on a plan is non-justiciable. | CoC must now record reasons for approving a plan |
| CoC of Essar Steel v. Satish Kumar Gupta | 15 Nov 2019 | CoC decides distribution; NCLT review is limited; 330 days is the ordinary outer limit; no undecided claims survive the plan. | Dissenting financial creditor minimum changed |
| Ghanashyam Mishra v. Edelweiss ARC | 13 Apr 2021 | Claims not in an approved plan, including Government dues, stand extinguished; the 2019 amendment to section 31 is clarificatory. | Codified in new section 31(6) |
| Lalit Kumar Jain v. Union of India | 21 May 2021 | The 15 November 2019 notification on personal guarantors is valid; plan approval does not discharge a personal guarantor. | Codified in section 31(6), Explanation I |
| Vidarbha Industries v. Axis Bank | 12 Jul 2022 | Section 7(5)(a) read as discretionary; NCLT could keep admission in abeyance on the facts. | Overtaken: admission is now mandatory when the conditions are met |
| State Tax Officer v. Rainbow Papers | 6 Sep 2022 | The State, with a statutory charge under the Gujarat VAT Act, was a secured creditor; a plan ignoring its dues was set aside. | Section 3(31) now excludes security interest created merely by operation of law |
| M. Suresh Kumar Reddy v. Canara Bank | 11 May 2023 | Vidarbha confined to its facts; Innoventive still holds good. | Consistent with new section 7(5) |
| Dilip B. Jiwrajka v. Union of India | 9 Nov 2023 | Sections 95-100 valid; the resolution professional's role is facilitative and no adjudication happens before section 100. | Section 96 interim moratorium no longer applies to personal guarantor applications |
Two Answers for Some Questions
For the exam, answer on the law as at 4 February 2025: Vidarbha's reading of section 7(5)(a) as recorded and later confined by Suresh Kumar Reddy, Rainbow Papers on statutory charges, and the old section 12A. In practice from 26 May 2026, the amended Code governs.
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How to Learn 72 Cases Without Memorising 72 Judgments
- 1
1. One line per case
Write the question the court answered and its answer. Skip the facts unless the facts are the rule (Vidarbha's ₹1,730 crore APTEL award is one).
- 2
2. Group by the provision
Put section 7 cases together (Innoventive, Vidarbha, Suresh Kumar Reddy), section 9 together (Mobilox), section 29A together (ArcelorMittal, Swiss Ribbons), section 31 together (Essar, Ghanashyam Mishra, Lalit Kumar Jain).
- 3
3. Note what overruled or confined what
Case-law MCQs like pairs: a later case narrowing an earlier one, or an amendment codifying a ruling.
- 4
4. Read the NCLAT and High Court entries at headline level
Annexure 1 also lists 12 High Court, 13 NCLAT and 6 NCLT decisions. Know which forum decided each and its one-line holding.
How the Limited Insolvency Examination Tests This
Direct case-law questions are short: which case held X, or what was held in Y. The harder use is inside a case study. A narrative describes a financial creditor's application, a CoC vote or a guarantor's plea, and the right answer is the one that applies a ruling without naming it.
The common trap is mixing up who decides what. Candidates give the NCLT a merits review of a plan (Essar and Sashidhar say no), treat a pre-existing dispute as irrelevant to a financial creditor (Mobilox is about section 9 only), or assume plan approval frees the promoter's personal guarantee (Lalit Kumar Jain says it does not).
FAQs
How many case laws are in the IBBI Limited Insolvency Examination syllabus?expand_more
Annexure 1 of the syllabus dated 4 February 2025 lists 72: 41 Supreme Court, 12 High Court, 13 NCLAT and 6 NCLT decisions. Five one-mark questions are asked on them directly.
Which IBC judgments are most important for the exam?expand_more
Swiss Ribbons, Essar Steel, Innoventive, Mobilox, ArcelorMittal, Ghanashyam Mishra, Lalit Kumar Jain and Vidarbha Industries come up most in case-study logic because they decide admission, plan approval and what an approved plan extinguishes.
Is Vidarbha Industries still good law?expand_more
The Supreme Court confined it to its facts in M. Suresh Kumar Reddy (2023). The IBC (Amendment) Act, 2026 then rewrote section 7(5) from 26 May 2026: the NCLT must admit within 14 days once a default, a complete application and no pending disciplinary proceeding against the proposed resolution professional are shown.
Does the exam test judgments delivered after February 2025?expand_more
The syllabus fixes the law as on 4 February 2025 and lists the cases it tests. Study the Annexure 1 list; a later ruling or amendment is not part of the current series.
Next steps
- Swiss Ribbons casearrow_forward
- Essar Steel casearrow_forward
- Vidarbha casearrow_forward
- Syllabusarrow_forward
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