Authored By: Komal Verma
Klmv, Prayagraj
Abstract
Section 240C of the Insolvency and Bankruptcy Code 2016, inserted by the Insolvency and Bankruptcy Code (Amendment) Act 2026, delegates to the Central Government the task of constructing India’s operational framework for cross-border insolvency. The provision authorises rules dealing with recognition of foreign proceedings, relief, judicial cooperation, assistance and coordination. It also permits the rules to modify or adapt provisions of the Code and the Companies Act 2013, designate specialised Benches, and apply to foreign limited-liability entities. The provision is therefore more consequential than a conventional rule-making clause: it supplies the legal basis for a future Part Z-type regime while leaving its substantive architecture unresolved.
This article argues that India should not choose between reciprocity and the UNCITRAL Model Law’s centre of main interests (‘COMI’) test as though they were rival jurisdictional doctrines. They answer different questions. Reciprocity determines which foreign systems may access India’s statutory cooperation framework; COMI determines whether a particular foreign proceeding is the debtor’s main proceeding. The appropriate model is consequently a staged and reviewable form of qualified reciprocity combined with a judicial COMI inquiry.
The article further argues that recognition should not automatically reproduce the domestic section 14 moratorium, and group insolvency should not be permitted to convert economic unity into substantive consolidation. Recognition-based relief should be asset-sensitive, time limited and conditioned on procedural fairness. Group proceedings should ordinarily involve procedural coordination, separate estates and separate voting rights. Consolidation should be exceptional and judicially ordered.
The proposed framework seeks to reconcile international cooperation with constitutional legality, creditor protection and the separate personality of corporate entities. It recommends transparent country notifications, evidence-based COMI rules, specialised NCLT Benches, foreign-representative regulation, model protocols and safeguards against strategic relocation.
Keywords
Cross-border insolvency; section 240C; COMI; reciprocity; group insolvency; moratorium; UNCITRAL Model Law; forum-shopping; Insolvency and Bankruptcy Code.
Introduction
The 2026 amendment to the Insolvency and Bankruptcy Code 2016 (‘IBC’) does not enact a complete cross-border insolvency code. Instead, it creates the authority to make one. Section 240C empowers the Central Government to prescribe the manner and conditions for
administering cross-border insolvency proceedings, including recognition, relief, judicial cooperation, assistance and coordination. The provision also permits the rules to adapt provisions of the IBC and the Companies Act 2013 and to designate one or more Adjudicating Authority Benches for cross-border matters.ibbi.gov+1
That legislative technique is both pragmatic and constitutionally sensitive. Cross-border insolvency requires procedural detail that is difficult to include in primary legislation: forms of recognition applications, documentary requirements, court-to-court communication, foreign-representative access, translation, asset-specific relief and treatment of concurrent proceedings. Delegated legislation can respond more quickly than a further statutory amendment.
The difficulty is that section 240C also touches matters that are not merely administrative. Recognition can prevent creditors from enforcing against Indian assets. Relief can affect secured creditors, lessors and public authorities. A finding that a foreign proceeding is the main proceeding can alter the strategic centre of a debtor’s restructuring. In group cases, coordination can influence the value and voting rights of creditors of legally separate companies. The rules must therefore remain within the statutory purpose and respect Articles 14, 21 and 300A of the Constitution.
The existing statutory framework is inadequate for this purpose. Sections 234 and 235 of the IBC contemplate bilateral agreements and letters of request. They do not provide a comprehensive recognition test, direct access for foreign representatives, consequences of recognition, rules for concurrent proceedings or a framework for enterprise groups. Their bilateral structure is particularly ill-suited to cases in which assets and creditors are spread across several countries.
The Insolvency Law Committee (‘ILC’) identified this problem in 2018 and recommended adoption of the UNCITRAL Model Law on Cross-Border Insolvency 1997 through a proposed Part Z. The ILC also recommended that India initially adopt the Model Law on a reciprocity basis, with the possibility of diluting that requirement after institutional experience had developed. The Cross Border Insolvency Rules/Regulations Committee (‘CBIRC’) later examined implementation questions, including COMI, foreign representatives, judicial cooperation, relief and specialised institutional arrangements.pib.gov+2
Section 240C reopens these choices. The question is no longer whether India should adopt a cross-border framework in principle. The question is what the rules should actually do.
This article advances a qualified-recognition model. Reciprocity should determine the jurisdictions whose courts and representatives receive access to the statutory framework. It should not determine whether an individual proceeding is a foreign main proceeding. That question should be decided judicially by applying COMI and establishment tests. Recognition should produce cooperation and proportionate relief, not automatic surrender of Indian jurisdiction. Group insolvency should enable procedural coordination while preserving separate corporate estates.
Research Questions
The article addresses five questions:
- What legal limits govern the Central Government’s rule-making power under section 240C?
- Should India use reciprocity, COMI, or a combination of both to recognise foreign proceedings?
- How should recognition-based relief interact with the domestic moratorium under section 14 of the IBC?
- How can group insolvency rules facilitate value-preserving coordination without authorising automatic substantive consolidation?
- What safeguards are necessary to prevent forum-shopping through artificial COMI relocation or group structuring?
Objectives
The article aims to:
- clarify the relationship between sections 234, 235 and 240C;
- distinguish reciprocity from COMI as regulatory devices;
- formulate a recognition and relief procedure suitable for Indian adjudicatory institutions;
- design safeguards for group insolvency and moratorium coordination; and • identify practical reforms capable of being incorporated into section 240C rules.
Research Methodology
The article uses doctrinal analysis of the Constitution, the IBC, the 2026 Amendment Act, the UNCITRAL Model Law and Indian case law. It also examines the ILC and CBIRC Reports as the principal Indian policy materials.
Comparative analysis is limited to the United States, the United Kingdom and Singapore. These jurisdictions are relevant because each has implemented the Model Law or a substantially similar framework, but they are not treated as templates to be transplanted mechanically. Their value lies in illustrating particular choices concerning COMI, automatic relief, judicial discretion and institutional capacity.
The article does not rely on unverified descriptions of the Go First proceedings for precise propositions of law. The procedural history and final orders in those proceedings should be checked against the official NCLT, NCLAT and foreign court records before publication. The discussion of Go First is therefore confined to the broader regulatory problems exposed by a debtor whose assets, lessors and creditors are distributed across jurisdictions.
Literature Review
The Indian literature has correctly identified the inadequacy of sections 234 and 235 and the advantages of the Model Law. It has been less successful in distinguishing the separate functions of reciprocity and COMI.
Reciprocity is a relationship between states. COMI is a connection between a debtor and a proceeding. The former concerns the availability of a statutory channel for cooperation; the latter concerns the classification of a particular proceeding as main or non-main. Treating them as substitutes creates analytical confusion. A country may offer effective judicial assistance without having enacted the Model Law, while a country that has enacted it may provide little practical assistance in a particular case.
The ILC’s initial reciprocity recommendation was institutionally defensible. India had no experience with a formal recognition regime and no established network of judicial cooperation. Reciprocity offered a means of limiting exposure while Indian courts and insolvency professionals developed capacity. But the recommendation was transitional by design. It cannot sensibly become a permanent requirement without periodic review.
The CBIRC Report addressed many of the operational issues that a future rule set would have to resolve. Its recommendations concerning COMI, designated Benches and foreign representative access are more important for present purposes than the general proposition that the Model Law should be adopted. Section 240C has now made implementation, rather than conceptual acceptance, the central research problem.
A substantial gap remains concerning group insolvency. The economic reality of a corporate group can justify coordination, but the legal reality remains entity-based. The insolvency of a parent does not, without more, place the subsidiary’s assets into the parent’s estate. Nor should a common resolution strategy eliminate the separate voting rights of creditors who contracted with different companies.
A related gap concerns the moratorium. Section 14 is triggered by admission of a domestic CIRP application and is framed around a particular corporate debtor. Recognition of a foreign proceeding is a different procedural event. The rules must therefore create a separate legal mechanism for recognition-based relief instead of assuming that section 14 automatically applies across borders.
Legal Framework
Constitutional limits
Article 14 requires that the classification of foreign countries, debtors or proceedings be based on relevant criteria. A notification excluding a country from the section 240C framework should therefore identify the reasons for exclusion. The Government may consider practical reciprocity, judicial cooperation and procedural fairness, but not irrelevant diplomatic or commercial preferences.
Article 21 is engaged because recognition and relief can restrict access to courts and enforcement mechanisms. The recognition procedure must provide notice, disclosure and a meaningful opportunity to object. A foreign representative should not obtain far-reaching relief merely by filing a foreign order without identifying affected Indian creditors and proceedings.
Article 300A reinforces the need for statutory authority and proportionality where recognition-based relief restrains dealings with property. Insolvency law may impose collective restraints, but the restraint must be connected to preservation of the estate and must not exceed what coordination requires.
Articles 245 and 246 establish Parliament’s legislative authority, while Article 253 permits legislation implementing international agreements. The UNCITRAL Model Law is not self executing. Its principles operate in India only through domestic legislation or validly delegated legislation. Section 240C therefore supplies the domestic source, but the rules cannot create substantive creditor priorities or liability regimes that the parent statute does not support.
Section 240C itself contains an important safeguard. Draft rules must be laid before both Houses of Parliament under the procedure incorporated from section 59A. This does not convert the rules into primary legislation, but it provides a measure of legislative scrutiny. The Central Government should use that procedure substantively by publishing explanatory notes, consultation responses and an assessment of the effect on creditor rights.icsiiip
Sections 234 and 235
Section 234 permits the Central Government to enter into agreements with foreign countries for applying the Code. Section 235 allows the Adjudicating Authority to issue a letter of request to a foreign court or authority where such an agreement exists.
The problem is structural. A letter of request is an assistance mechanism, not a recognition regime. It does not answer whether a foreign proceeding should be treated as main or non main, whether the foreign representative may appear directly before the NCLT, or what relief should follow recognition.
Section 240C should therefore operate as the specialised route for countries and debtor classes brought within the notified framework. Sections 234 and 235 may continue to govern bilateral assistance outside that framework, but they should not be used to reproduce section 240C recognition consequences without equivalent safeguards.
Section 240C
The wording of section 240C is broad but not unlimited. Subsection (1) authorises rules concerning recognition, relief, cooperation, assistance and coordination for notified classes of debtors or corporate debtors involving notified countries or territories. Subsection (2) permits exceptions, modifications and adaptations to the IBC and the Companies Act where required to administer the cross-border framework. It also permits designation of Benches.vinodkothari
The power to modify or adapt provisions should be read narrowly. It permits procedural adjustment, not legislative reconstruction. For example, a rule may adapt filing requirements to accommodate a foreign representative. It should not alter the statutory waterfall under section 53, create a new class of secured creditor or deprive a creditor of a substantive defence.
The Explanation to section 240C extends “corporate debtor” to include a person incorporated with limited liability outside India. This is necessary to prevent the framework from being confined to Indian-incorporated companies, but it also makes the definition of the covered debtor central to the rules. The rules should specify whether foreign-incorporated entities must have assets, operations, creditors or a proceeding connected with India before the NCLT can exercise jurisdiction.indiacorplaw
The Model Law
The UNCITRAL Model Law is deliberately procedural. It seeks access, recognition, relief, cooperation and coordination without unifying the substantive insolvency laws of enacting states. Recognition of a foreign main proceeding is ordinarily linked to the debtor’s COMI at the date of commencement; recognition of a non-main proceeding is linked to an establishment.dsklegal
The Model Law does not require unconditional deference. It allows a recognising court to grant interim and discretionary relief, protect local interests and refuse action contrary to public policy. Its central premise is cooperation under judicial supervision, not the displacement of domestic law.
The domestic moratorium
Section 14 restrains proceedings against the corporate debtor after admission of a CIRP application. It protects the collective insolvency process from individual enforcement and preserves the value of the debtor as a going concern.
The section 14 moratorium is not automatically group-wide. The separate legal identity of a subsidiary, parent or affiliate remains relevant unless the statute or a judicial order provides otherwise. The Supreme Court’s insolvency jurisprudence has consistently treated the IBC as a collective process, but collective administration does not eliminate the distinction between separate debtors.
A foreign recognition order should therefore not be described as an extension of section 14. It should be based on a separate recognition-relief rule authorised by section 240C.
Case Law Analysis
Jet Airways
In State Bank of India v Jet Airways (India) Ltd, the NCLAT approved a cross-border insolvency protocol involving the Indian resolution professional and a Dutch trustee. The case is important because it demonstrated that cooperation could be achieved through judicial innovation despite the absence of a comprehensive statutory framework.mssulthan
Its deeper lesson is less celebratory. A protocol negotiated in one case cannot supply a general recognition standard. It leaves unanswered who may apply, what evidence establishes a foreign proceeding, what relief is automatic, how creditors are heard, and how conflicts between domestic and foreign proceedings are resolved.
Section 240C should preserve protocols but place them within a rule-based framework. A model protocol should address information exchange, confidentiality, claims reconciliation, avoidance proceedings, asset control, costs, privilege, court communication and termination. The protocol should supplement, not replace, the recognition order.
Go First
The Go First proceedings demonstrate why cross-border rules must be sensitive to the asset involved. Aircraft, engines, leases and maintenance arrangements cannot be treated in the same manner as ordinary corporate assets. A stay that preserves the going-concern value of an airline may simultaneously increase the lessor’s exposure to depreciation, insurance and maintenance risk.
The lesson for the rules is that recognition-based relief should be conditional. The NCLT should have power to require insurance, maintenance, preservation payments, access to records and periodic reporting. Relief should protect the estate without transferring the cost of preservation unfairly to an asset owner who is not participating in the foreign proceeding.
The exact legal propositions arising from Go First require verification from the official orders. The case should not be cited as establishing a general rule on foreign asset ownership or lessor rights unless the relevant order is identified precisely.
Supreme Court doctrine
Three strands of Supreme Court doctrine are relevant.
In Innoventive Industries Ltd v ICICI Bank, the Court treated the IBC as a comprehensive code designed to address insolvency through a collective process. Cross-border recognition advances that objective where fragmented enforcement would destroy value.indiacode.nic
In Swiss Ribbons Pvt Ltd v Union of India, the Court emphasised the Code’s resolution oriented purpose and its concern with preserving the corporate debtor as a going concern. That objective supports recognition, but it does not justify relief that disregards creditors whose rights are governed by Indian law.indiacode.nic
In Committee of Creditors of Essar Steel India Ltd v Satish Kumar Gupta, the Court protected the commercial role of the committee of creditors while retaining statutory and judicial controls. International cooperation should be approached in the same manner. Cooperation is a means of achieving the statutory objective; it is not an independent source of power.revisedacts.lawreform
Comparative Jurisprudence
The United States, the United Kingdom and Singapore demonstrate that COMI-based recognition can coexist with significant judicial control.
Chapter 15 of the United States Bankruptcy Code distinguishes foreign main and non-main proceedings and separates recognition from the grant of discretionary relief. The United States model is useful because it treats registered office as evidence rather than an irrebuttable conclusion.
The United Kingdom’s Cross-Border Insolvency Regulations 2006 show the importance of objective and externally ascertainable COMI. A debtor should not be able to establish its principal administration merely through internal documents prepared after default.
Singapore illustrates the importance of institutional readiness. Recognition rules are effective only when courts, insolvency professionals and registries can process foreign documents, manage communication and issue timely directions.
The comparison supports a functional division:
Regulatory question Appropriate test
Which jurisdictions receive access to the statutory framework?
Is the foreign proceeding the debtor’s main
Notification based on qualified reciprocity
proceeding? Judicial COMI inquiry Does the debtor have a non-main establishment? Evidence of stable local operations What relief should be granted? Proportionality, necessity and creditor protection Should group entities be consolidated? Separate exceptional judicial inquiry
Critical Analysis
Reciprocity and COMI perform different functions
Reciprocity should not be rejected simply because the Model Law does not require it. India’s institutional caution is legitimate. The ILC’s proposal recognised that a new regime must develop through practice.
The problem is not reciprocity itself but the absence of a functional definition. Formal enactment of the Model Law should not be the exclusive criterion. A foreign state should qualify where Indian representatives and creditors can obtain effective access, recognition and cooperation under its law and practice.
The Government should maintain a schedule of notified jurisdictions, accompanied by reasons and reviewed every three years. The notification should be open to administrative reconsideration and judicial review on ordinary public-law grounds. Recognition already granted should not be retrospectively invalidated merely because a jurisdiction is later removed from the schedule.
Once a jurisdiction is notified, the NCLT should still decide whether the proceeding satisfies the Model Law-style requirements. Reciprocity is an access filter; COMI is a classification test.
COMI and forum-shopping
The registered office should create a rebuttable presumption, not a conclusive rule. The court should examine central administration, strategic decision-making, treasury functions, books and records, principal creditors, operations and representations made to counterparties.
The perspective should be objective. COMI is not established by what the debtor now asserts about itself. It is established by the place that reasonably appeared to creditors and commercial counterparties to be the centre from which the debtor was administered.
The relevant date should be the commencement of the foreign proceeding. A change in registered office or management during the preceding twelve months should trigger additional disclosure and scrutiny. A relocation after insolvency became reasonably foreseeable should not automatically defeat recognition, but it should deprive the applicant of any easy presumption.
Recognition and relief
Recognition should confer procedural access and enable the foreign representative to seek assistance. It should not automatically transfer Indian assets or alter domestic distribution priorities.
The rules should distinguish:
- interim relief before recognition;
- limited automatic consequences following recognition of a foreign main proceeding; and
- discretionary relief following recognition of either a main or non-main proceeding.
Automatic relief should be narrow: restraint on transfer of identified Indian assets and suspension of individual enforcement where necessary to preserve the estate. It should not prevent regulatory action, criminal investigation, employee claims or proceedings against persons other than the debtor.
Discretionary relief should be conditioned on notice, undertakings, insurance, preservation costs and protection of secured creditors. The court should be able to modify or terminate relief when the foreign proceeding changes or when the relief produces disproportionate prejudice.
Group insolvency
The rules should separate procedural coordination from substantive consolidation.
Procedural coordination may include common hearings, shared information, coordinated valuation, a common lead professional and a group resolution plan. Each debtor should retain a separate claims register and creditor vote.
Substantive consolidation should require evidence of exceptional circumstances: pervasive commingling, sham entities, inability to identify assets and liabilities, or conduct that caused creditors reasonably to treat the group as a single enterprise. Common ownership, common branding and cross-guarantees should not suffice.
The rules should require entity-specific disclosure of the effect of a group plan. Creditors of a subsidiary should be able to demonstrate that coordination reduces their expected recovery or deprives them of a remedy available against that subsidiary alone.
Moratorium coordination
A recognition-based stay should be separate from section 14. It should be directed at the consequences of the foreign proceeding rather than described as an automatic Indian CIRP moratorium.
The NCLT should have three forms of relief:
- preservation of identified assets;
- stay of specified enforcement actions; and
- coordination orders governing concurrent proceedings.
Each order should identify its duration, affected assets and affected parties. Relief over leased or revenue-generating assets should ordinarily require compensation or preservation undertakings. A group-wide stay should be impermissible unless each affected entity is separately recognised or a reasoned order establishes that the entities’ assets cannot practically be separated.
Challenges
Delegated legislation
Section 240C’s power to permit modifications and adaptations is necessary but potentially expansive. The rules must not amend substantive creditor priorities, create new causes of action or impose liabilities beyond the IBC.
The parliamentary laying requirement should be used meaningfully. Draft rules should be accompanied by a clause-by-clause explanation of every modification to the IBC or Companies Act and an impact statement identifying affected creditors.
Institutional capacity
Cross-border cases require familiarity with foreign orders, evidence, translation and conflicts of law. The Government should designate specialised NCLT Benches or cross-border coordinators, but specialisation should not create an unreasoned jurisdictional monopoly. A national practice direction could promote consistency while preserving access.
Foreign representatives
Foreign representatives should be admitted through a registration or authorisation process rather than required to qualify as Indian insolvency professionals. They should provide an Indian address for service, disclose conflicts, comply with confidentiality obligations and accept the supervisory jurisdiction of the NCLT.
Sectoral regulation
Recognition should not disable the Reserve Bank of India, securities regulators, aviation authorities, tax authorities or other statutory bodies. The NCLT should coordinate with regulators, but the rules should preserve regulatory action necessary for public safety, financial stability and statutory supervision.
Data and confidentiality
Cross-border cooperation necessarily involves data transfer. The rules should allow protective orders, restrict use of information to the recognised proceeding and permit sanctions for unauthorised disclosure. Foreign representatives should not receive unrestricted access to personal or commercially sensitive data.
Recommendations
The following provisions should be incorporated into the section 240C rules.
Notification
The Central Government should notify jurisdictions on the basis of functional reciprocity, considering:
- access available to Indian insolvency professionals and creditors;
- practical recognition of Indian proceedings;
- procedural fairness;
- judicial cooperation;
- enforceability of foreign orders; and
- compatibility with Indian public policy.
Notifications should state reasons, be reviewed periodically and operate prospectively.
Recognition application
An applicant should file:
- the foreign commencement order;
- proof of appointment of the foreign representative;
- evidence concerning COMI or establishment;
- a list of Indian assets and proceedings;
- a list of known Indian creditors;
- disclosure of recent changes in registered office or central administration; and • a statement identifying related group entities.
The NCLT should issue notice to the debtor, affected creditors, Indian insolvency professionals and relevant regulators.
COMI
The rules should provide a rebuttable registered-office presumption and a non-exhaustive list of objective factors. COMI should be assessed as at the commencement of the foreign proceeding. Relocation during the preceding twelve months should require enhanced disclosure.
Relief
Relief should be necessary, proportionate, asset-sensitive and reviewable. The NCLT should be able to require preservation undertakings, insurance, compensation for use and periodic reporting.
Group insolvency
The rules should authorise procedural coordination and group resolution plans while preserving separate estates and voting rights. Substantive consolidation should require exceptional evidence and a separate judicial order.
Protocols
The IBBI should publish a model cross-border protocol covering:
- court communication;
- information exchange;
- confidentiality;
- claims reconciliation;
- avoidance proceedings;
- allocation of costs;
- asset control;
- treatment of inter-company claims; and
- dispute resolution.
Review
The rules should be reviewed after three years. The review should examine recognition applications, relief orders, creditor outcomes, country notifications, professional conduct and the frequency of group coordination or consolidation orders.
Conclusion
Section 240C creates the legal opening for India’s long-delayed cross-border insolvency framework. Its success will depend less on whether the rules use the language of the UNCITRAL Model Law than on whether they allocate authority carefully between the Central Government, the NCLT, the IBBI and foreign courts.
India should adopt qualified reciprocity, but only as a temporary and reviewable access condition. COMI should remain a judicial inquiry directed to the debtor’s actual and objectively ascertainable centre of administration. Recognition should facilitate cooperation without displacing Indian substantive law. Relief should be proportionate and conditioned where local creditors, lessors or regulators would otherwise bear the cost of an order made for the benefit of a foreign estate.
Group insolvency presents the sharper test. Corporate groups operate as economic networks, but creditors contract with legal entities. The rules should therefore permit coordinated administration without treating economic integration as proof that the entities share one insolvency estate. Substantive consolidation should remain exceptional.
A carefully designed Part Z regime would advance the IBC’s value-preservation objective while respecting constitutional legality and corporate separateness. A poorly designed regime would merely transfer uncertainty from sections 234 and 235 to delegated legislation. The present rule-making window should be used to avoid that result.
Editorial and Citation Note
The principal correction to the earlier draft is the treatment of section 240C. The provision does not merely authorise rules concerning recognition and cooperation. It also permits modifications and adaptations of the IBC and Companies Act, designates Benches and subjects draft rules to parliamentary laying requirements. Those features materially affect the delegation analysis and have been incorporated above.prsindia
The discussion of Go First has been narrowed because precise propositions should not be attributed to the proceedings without verified official orders. The Jet Airways citation should be checked against the official NCLAT record before submission, particularly the appeal number, date and paragraph references. The Supreme Court citations below are established reporter citations, but the journal should conform them to its preferred OSCOLA table of cases.
Insolvency and Bankruptcy Code 2016, s 240C(1), inserted by the Insolvency and Bankruptcy Code (Amendment) Act 2026, s 71.ibbi.gov
IBC 2016, s 240C(2).uncitral.un
Insolvency Law Committee, Report on Cross-Border Insolvency (Ministry of Corporate Affairs, October 2018).pib.gov
ibid.livelaw
Cross Border Insolvency Rules/Regulations Committee, Report on the Rules and Regulations for Cross-Border Insolvency (Ministry of Corporate Affairs, June 2020).iiipicai
IBC 2016, s 240C(3).icsiiip
IBC 2016, s 240C(2).vinodkothari
IBC 2016, s 240C, Explanation.indiacorplaw
UNCITRAL, UNCITRAL Model Law on Cross-Border Insolvency with Guide to Enactment and Interpretation (1997, as revised in 2013).dsklegal
State Bank of India v Jet Airways (India) Ltd, Company Appeal (AT) (Insolvency) No 707 of 2019, NCLAT, judgment dated 26 September 2019. The official order should be consulted for final citation and paragraph references.mssulthan
Innoventive Industries Ltd v ICICI Bank (2018) 1 SCC 407.indiacode.nic Swiss Ribbons Pvt Ltd v Union of India (2019) 4 SCC 17.indiacode.nic
Committee of Creditors of Essar Steel India Ltd v Satish Kumar Gupta (2020) 8 SCC 531.revisedacts.lawreform
The official Gazette text confirms that the 2026 Act received presidential assent on 6 April 2026 and that section 240C contains provisions on recognition, relief, cooperation, adaptations, designated Benches and parliamentary laying. The UNCITRAL description confirms that the Model Law is directed to access, recognition, relief, cooperation and coordination without unifying substantive insolvency law
