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

Order Date: 16/06/2026

Case Overview

The application (IA/752(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 NCLT Rules, 2016. The applicant sought condonation of delay in submitting its claim and a direction for the Resolution Professional (RP) to consider it in the Personal Insolvency Resolution Process (PIRP) of Mr. Anilkumar Ramkishan Agrawal, who is the Personal Guarantor to the corporate debtor, M/s JRA Infrastructure Limited. The PIRP was admitted on 16.10.2025. HDFC Bank submitted its claim in Form-B on 30.04.2026, which was rejected by the RP on 02.05.2026 solely on the grounds of it being submitted beyond the prescribed period. The bank argued the delay occurred due to the transfer of the loan account, verification of records, reconciliation of dues, and collection of supporting documents. The RP contended that the bank was aware of the proceedings and the public announcement (dated 19.10.2025) and that the process had substantially progressed before the claim was filed. The existence of the underlying debt, stemming from financial facilities extended to JRA Infrastructure Ltd. and a General Form of Guarantee dated 01.11.2021, was not disputed.

The Tribunal considered judgments cited by the parties, including the Hon'ble Supreme Court's ruling in Greater Noida Industrial Development Authority v. Prabhjit Singh Soni & Anr., which held that a Resolution Professional is required to collate information from claims and available records. The Adjudicating Authority concluded that while timelines under the Code are important, a verifiable claim should not be excluded without examination on merits 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, Mr. Rajendra Devidas Puranit, was directed to verify and consider the claim submitted by HDFC Bank through Form-B dated 30.04.2026 (referenced in the order as 02.05.2026) along with its supporting documents in accordance with the Insolvency and Bankruptcy Code, 2016 and its applicable Rules and Regulations. The order clarifies that it does not constitute an admission of the claim or a determination of its quantum; those decisions are left to the RP.

Topics: Insolvency, Banking