Authority: National Company Law Tribunal (NCLT), Division Bench, Court - 1, Ahmedabad

Order Date: 16/06/2026

Case Overview

This application (IA/749(AHM)2026) was filed by HDFC Bank Limited under Section 60(5) of the Insolvency and Bankruptcy Code, 2016, read with Rule 11 of the National Company Law Tribunal Rules, 2016. The bank sought condonation of a delay in submitting its claim in the Personal Insolvency Resolution Process (PIRP) of Mr. Sanjaykumar Jugalkishor Agrawal, who is the Personal Guarantor for the corporate debtor, M/s JRA Infrastructure Limited.

The PIRP against the guarantor was initiated by an order dated 16/10/2025. HDFC Bank submitted its claim in Form-B on 02/05/2026 for an amount of ₹1.02 crore. This claim was based on financial facilities extended to JRA Infrastructure Limited and a guarantee obligation undertaken by Mr. Agrawal, documented in a General Form of Guarantee dated 01/11/2021 and a Sanction Acceptance Letter dated 03/06/2024.

The Resolution Professional (RP), Mr. Rajendra Devidas Puranit, rejected the claim via a Claim Non-Admission Note dated 05/05/2026 solely on the grounds that it was submitted after the prescribed timeline following the public announcement made on 19/10/2025. The RP argued that the bank was aware of the proceedings, and the process had substantially progressed before the claim was filed.

HDFC Bank contended that the delay occurred due to the transfer of the loan account, the need for verification of records, reconciliation of dues, and the collection of necessary supporting documents. It argued that the debt was verifiable from existing records. The bank relied on judicial precedents, including the Supreme Court judgment in Greater Noida Industrial Development Authority v. Prabhjit Singh Soni & Anr. (2024) and the NCLAT decision in Puneet Kaur v. KV Developers Private Limited & Ors. (2022), which support the consideration of delayed claims upon showing sufficient cause.

The Adjudicating Authority (comprising Mr. Shammi Khan, Member (J) and Mr. Sanjeev Sharma, Member (T)) noted that the existence of the underlying debt and guarantee was not disputed. The rejection was purely procedural, based on lateness. The tribunal emphasized that while timelines under the Code are important, a verifiable claim should not be excluded without a merits examination if sufficient cause for the delay is shown.

Final Outcome

The NCLT allowed the application. The delay in submitting the claim was condoned. The Resolution Professional was directed to verify and consider the claim filed by HDFC Bank (Form-B dated 02/05/2026) along with its supporting documents on its merits, in accordance with the provisions of the Insolvency and Bankruptcy Code, 2016, and its applicable Rules and Regulations. The order explicitly clarifies that it does not constitute an admission of the claim's validity or its quantum; that determination is left to the RP following due process. The application was disposed of with no order as to costs.

Topics: Insolvency Resolution, Banking Claims, Judicial Adjudication