Corporate Insolvency Resolution Process (CIRP) Under IBC - An Analysis Of Effectiveness And Challenge

Author: LawSphereX

Category: Corporate & Insolvency

Published: 2026-08-23T19:00:34.319Z

Updated: 2026-08-30T07:10:56.064Z

CORPORATE INSOLVENCY RESOLUTION PROCESS

(CIRP) UNDER IBC: AN

ANALYSIS

OF EFFECTIVENESS

AND

CHALLENGE

Rajat Sharma, Faculty of Law College Dehradun, Uttaranchal University Bhawna Arora, Associate Professor, Law College Dehradun, Uttaranchal University Introduction India's Insolvency and Bankruptcy Code 2016 has handled 8,002 cases through the Corporate Insolvency Resolution Process (CIRP) by September 2024. This marks a major step forward in the country's insolvency system. The closed cases show promising results - 75% have found resolution through different approaches. The success rate of resolutions compared to liquidations has jumped from 21% in 2017-18 to 61% in 2023-24. The system still faces some roadblocks. Cases take 683 days on average to resolve, which goes well beyond the 180-day target. This points to vital implementation issues that need attention. The numbers tell an interesting story about recovery rates.

Financial creditors get back 32% of their claims, and operational creditors recover about 25%. Liquidation cases paint an even grimmer picture. Only INR 8,943 crores came back from admitted claims of INR 228,702. 84 crores - a tiny 3% recovery rate. Our analysis will get into how CIRP works under the IBC framework and what challenges it faces. We want to look at the legal structure, important case laws, and implementation hurdles. We'll also see how India's system stacks up against global standards. This deep dive will help us learn about how IBC actually performs versus its goals and what changes could make it better. Understanding CIRP under the Insolvency and Bankruptcy Code 2016 The Corporate Insolvency Resolution Process (CIRP) stands as the life-blood of India's insolvency framework under the Insolvency and Bankruptcy Code 2016.

This process offers a well-laid-out approach to corporate insolvency. The main goal focuses on reviving businesses rather than liquidating them. Let's take a closer look at how this process works. What is CIRP and when does it apply? CIRP works as a legally binding and time-bound process to resolve corporate debtors' insolvency. Everything starts the moment a corporate debtor fails to pay its creditors. Section

6 of the IBC allows CIRP against a corporate debtor after a payment default. The minimum

threshold to start proceedings now stands at ₹1 crore [1]. This amount saw an increase from ₹1 lakh in March 2020 [1]. These three groups can start the CIRP:

1. Financial creditors (banks, bondholders, homebuyers) under Section 7

2. Operational creditors (suppliers, service providers, employees) under Section 9

3. The corporate debtor itself under Section 10.[2]

CIRP aims to maximize asset value, boost entrepreneurship, and balance stakeholder interests. It tries to keep the corporate debtor running as a "going concern" whenever possible [3]. Unlike older frameworks, CIRP puts revival first and sees liquidation as the last option [3]. Key stages of CIRP: From default to resolution CIRP follows a clear path from start to finish that includes six distinct stages: Stage 1: Petition to NCLT - After a default, creditors or the corporate debtor file their petition with the National Company Law Tribunal (NCLT). The tribunal looks at the petition's merit and decides within 14 days [3]. Stage 2: Appointment of Interim Resolution Professional (IRP) - Once the petition gets accepted, NCLT brings in an IRP. This professional runs the company while keeping it operational [3].

Stage 3: Moratorium Period - This significant phase starts after petition acceptance. Legal proceedings against the corporate debtor stop during moratorium. No one can foreclose, recover, or transfer property [3].

Stage 4: Collation and Analysis of Claims - The IRP organizes and checks all creditor claims. The IRP must form the Committee of Creditors (CoC) within 30 days [3]. Stage 5: Resolution Plan - The CoC asks potential investors or bidders for resolution plans. These plans show how to fix the corporate debtor's insolvency. Plans need 66% CoC approval to reach NCLT [1]. Stage 6: Final Decision - NCLT either approves the resolution plan, making it binding for everyone, or orders liquidation if no plan works [3]. The whole ordeal must finish within 180 days. Complex cases might get 90 extra days. The law requires completion within 330 days maximum, including any legal battles [1]. Role of the Resolution Professional and Committee of Creditors Resolution Professionals (RP) serve as the life-blood of the insolvency process.

An Interim Resolution Professional starts things off, and the CoC might keep them or choose someone new. RPs run the corporate debtor's operations, protect asset value, and manage the CIRP [4]. RPs must handle these tasks: ● Keep the corporate debtor running ● Gather asset, financial, and operational information ● Create information packages for potential resolution applicants ● Process and track claims ● Show resolution plans to the CoC [4] The Supreme Court's ruling in Swiss Ribbon Pvt. Ltd v. Union of India clarifies that RPs help facilitate resolution rather than make judgments [4]. The Committee of Creditors (CoC) makes all the big decisions in CIRP. Only financial creditors can join the CoC, and courts respect their "commercial wisdom" in deciding the corporate debtor's future [5].

All but one of these creditors - operational creditors - don't deal very well with assessing business viability or helping with financial restructuring [5]. The CoC's authority includes: ● Choosing or changing the Resolution Professional ● Giving the green light to resolution plans (needs 66% votes) ● Starting liquidation if resolution fails ● Backing the RP's key administrative choices ● Setting CIRP expense limits [6] This integrated approach combines professional management and creditor oversight. CIRP balances everyone's interests while focusing on saving companies rather than closing them down. Legal Framework and Key Case Laws Shaping CIRP The Supreme Court of India's landmark judgments have shaped how we implement and interpret the Corporate Insolvency Resolution Process under the Insolvency and Bankruptcy Code 2016.

These court decisions have cleared up constitutional issues, put creditor committees first, and protected stakeholder rights in the insolvency ecosystem. Swiss Ribbons v. Union of India: Constitutional validity of IBC The Supreme Court made a groundbreaking decision in Swiss Ribbons Pvt. Ltd. & Anr. v. Union of India & Ors. in January 2019. The court gave a complete validation of IBC's constitutional standing [7]. This case looked at several challenges to the Code, with a focus on how financial and operational creditors were treated differently. People who filed the case said IBC's way of classifying creditors went against Article 14 of the Constitution. They claimed it discriminated between financial and operational creditors. The Supreme Court disagreed and established these points:

1. The difference between financial and operational creditors makes sense and connects

logically to what the law wants to achieve

2. Financial creditors are usually banks that give large secured loans, while operational

creditors provide goods and services with smaller, unsecured claims

3. Financial creditors have the technical know-how and access to financial data that helps

them judge if a business can survive [8] The Court made a notable observation that "the defaulter's paradise is lost" and stressed that the Code focuses more on helping companies recover than shutting them down [8]. This decision brought legal clarity and boosted investor faith in the IBC system. Essar Steel case: Commercial wisdom of CoC The Essar Steel India Ltd. v. Satish Kumar Gupta & Ors. case in 2019 brought another vital change to IBC law. This complex case, which took over two years, dealt with how money should be split among different creditor groups [9]. The Supreme Court set several basic principles:

1 Primacy of Committee of Creditors

The Court said that CoC's business decisions deserve respect from judges. The financial creditors' "commercial wisdom" should stay free from interference by legal authorities [10]

2 Equitable but Not Equal Treatment

The Court explained that "equality" doesn't mean all creditors should get similar recovery percentages. Different treatment between financial and operational creditors, and between secured and unsecured creditors, can work [9]

3 Limited Judicial Review

The Court set boundaries for when judges can step in.

NCLT/NCLAT cannot act like courts with full power to reverse CoC decisions [11]

4 Fresh Slate Theory

The Court supported letting resolution applicants start their business operations with a "fresh slate" without old debts [10] Justice Nariman's words in the judgment were clear: "What is left to the majority decision of the CoC is the 'feasibility and viability' of a resolution plan, which obviously takes into account all aspects of the plan, including the manner of distribution of funds among the various classes of creditors" [11]. Jaypee Infratech case: Treatment of homebuyers The Jaypee Infratech Ltd. case showed how IBC could adapt to handle unique stakeholder needs. This insolvency process started in August 2017, and thousands of homebuyers worried about their investments in unfinished housing projects [12]. The case brought these key changes:

1 Recognition of Homebuyers as Financial Creditors

The Court confirmed that homebuyers count as financial creditors. This gave them a voice in the CoC and acknowledged their financial stake [13]

2 Protection of Homebuyer Rights

The Court emphasized protecting homebuyers' interests during insolvency cases

3 Timeline Management

The Supreme Court used its powers under Article 142 to reset CIRP timelines. They stated: "the initial period of 180 days for the conclusion of the CIRP in respect of JIL shall commence from the date of this order" [14] After five years of legal proceedings, the case found its solution with the Suraksha group's winning bid. Their plan included giving flats to homebuyers who had paid more than 80% of their dues [13][2]. These landmark judgments show how courts have refined the IBC framework. They've balanced creditor rights with broader economic goals and helped establish India's insolvency system as a sophisticated tool for corporate revival and debt resolution. Effectiveness of CIRP: Data and Trends from IBBI Reports IBBI data shows us how CIRP implementation works in practice, and it paints an interesting picture of wins and ongoing challenges in India's insolvency ecosystem.

The real-life implementation of corporate insolvency differs quite a bit from what the IBC framework expected. Average resolution time vs statutory limit of 330 days The IBC wants resolutions within 330 days, but the actual time needed is nowhere near this target. IBBI quarterly newsletters tell us that the average time to approve resolution plans keeps growing - from 529 days for 493 processes in March 2022 to 613 days for 683 processes in March 2023. The numbers soared to 858 days for 208 processes between April-December 2023 [15]. Liquidation orders face the same issue. They took 414 days in March 2022, 456 days in March 2023, and jumped to 661 days between April-December 2023 [15]. Recent ICRA data shows resolution plans now take 843 days in FY2024, and liquidation cases need 679 days [16]. This big gap between expected and actual timelines comes from:

1. NCLT doesn't have enough capacity

2. Marketing stressed assets is tough

3. Corporate debtors don't cooperate

4. Documentation models need work [17]

Recovery rates for financial and operational creditors Different creditors see different recovery outcomes. Creditors have gotten back about 32% of their admitted claims [18] through resolution. The sort of thing I love is how resolution time links to recovery rates - cases wrapped up within 330 days get back 49%, but this drops to 26% when they drag beyond 600 days [19]. Financial creditors usually get better returns than operational ones. IBBI data shows financial creditors recovered about 30.09% of admitted claims [3]. Each sector tells its own story: ● Financial creditors do best in Hotels/Restaurants and Construction.

● Operational creditors see highest returns in Wholesale/Retail Trade and Hotels/Restaurants. ● Transport/Storage/Communications gives operational creditors their lowest returns, while Electricity/Gas/Water Supply does the same for financial creditors. [18] Recovery rates have dropped from 36% in FY2023 to 27% in FY2024, pushing the haircut from 64% to 73% [16]. Success rate of approved resolution plans The CIRP framework shows better resolution success rates despite timing issues. Resolutions compared to liquidations jumped from 21% in 2017-18 to 61% in 2023-24 [3]. This shows a move toward saving companies rather than shutting them down. Since it started until September 2024, CIRP has taken in about 8,002 cases and closed 75% of them [3].

This is a big deal as it means that 56% of closed cases were resolved, settled, or withdrawn - showing we're getting better at avoiding liquidation [3]. Money-wise, CIRP has helped recover around Rs 3. 55 lakh crore through 1,068 cases until September 2024 [20]. Looking at 987 resolved cases till FY2024, 15% finished within the 330day target [16]. Resolution plans have delivered 87. 58% of corporate debtors' fair value and 162. 8% of liquidation value. These numbers prove that resolution saves much more economic value than liquidation [21]. Challenges in CIRP Implementation in India The Corporate Insolvency Resolution Process (CIRP) has a well-laid-out design, yet it struggles with major implementation problems that affect its ability to work in India's business ecosystem.

These challenges weaken the core goals of the Insolvency and Bankruptcy Code (IBC) 2016, especially when it comes to quick resolution and maximizing value for stakeholders.

Judicial delays and NCLT capacity issues The National Company Law Tribunal (NCLT) struggles with severe capacity limits that directly affect CIRP timelines. Only 15 benches across India handle thousands of cases, which overwhelms the judicial system and creates substantial delays [8]. This bottleneck goes against IBC's time-bound approach and reduces stakeholder faith in the resolution process. The average time to complete CIRP has now reached 683 days - far beyond the 330-day legal limit [8]. Several factors cause these delays:

1. Complex procedures and court backlogs

2. Too many interim applications from non-stakeholders who try to derail proceedings

3. Cases that need multiple hearings

4. Not enough NCLT members (55 members instead of the approved 63) [4]

These delays reduce the chances of successful corporate revival substantially. Each extra day in the process makes assets lose value, creates more uncertainty for workers, and reduces creditors' legitimate claims [8]. Non-cooperation from promoters and management Resolution Professionals (RPs) often face strong resistance when taking control from promoters, who typically want to regain control at lower valuations [22]. This resistance shows up in several harmful ways: ● They refuse to share important company records and don't hand over management [23] ● They convince employees not to support CIRP implementation ● They ask customers to hold back payments ● They tell vendors not to extend credit [22] RPs face two big problems because of these tactics - they can't collect debts or pay vendors on time, which hurts working capital and daily operations [22].

Without promoters helping to provide detailed company information, potential buyers might submit much lower bids [22]. The Ram v. Interim Resolution Professional case shows how the Adjudicating Authority found that "the Promoters had neither handed over the records nor the management of the Corporate Debtor to the IRP. " This forced the IRP to resign and put the whole resolution process at risk[23]. Use of CIRP as a recovery tool by operational creditors Operational creditors now often use CIRP just to collect debts rather than fix struggling companies [5]. Several reasons make this attractive: ● Low application fees for operational creditors (₹2,000) compared to high civil litigation costs. [5] ● Quick CIRP process versus long civil recovery cases. [5] ● It works well as a negotiation tool to force settlements.

Numbers prove this trend - operational creditors filed more cases (3,667) than financial creditors (3,440). Many more operational creditor cases (756) were withdrawn under Section 12A after settlements [8]. In Asset Advisory Services v. VSS Projects, NCLAT made it clear that starting CIRP just to recover debt misuses IBC provisions [5]. The tribunal said declaring a company insolvent would be premature when the real goal was just debt recovery [5]. Comparing CIRP with Global Insolvency Frameworks India's CIRP framework takes a unique hybrid approach to insolvency resolution that sets it apart from global insolvency regimes. A closer look at these differences shows ways to improve IBC's implementation. Chapter 11 in the US: Debtor-in-possession model The US Chapter 11 procedure differs greatly from India's creditor-in-control CIRP model.

The existing management keeps control as "debtor-in-possession" (DIP) and runs business operations throughout bankruptcy [6]. This strategy helps preserve institutional knowledge.

Companies file earlier because management doesn't face displacement threats. The debtor gets 120 days to propose a reorganization plan and 180 days to secure confirmation[6]. Chapter 11's focus stays on preserving going-concern value rather than liquidation. The system believes existing management can best direct the company through its challenges [24]. UK's administration process under Insolvency Act 1986 The UK framework under the Insolvency Act 1986 provides valuable insights compared to India's CIRP. An external administrator takes control of the company as a court officer [24] once administration begins. This administrator's duties extend to all creditors, not just secured lenders, similar to India's approach.

The UK system follows clear objectives in order: rescue the company as a going concern, achieve better creditor outcomes than liquidation, and lastly realize property for secured or preferential creditors [25]. The Enterprise Act 2002 made rescue culture stronger by simplifying administration's entry and exit processes [26]. UNCITRAL Model Law on Cross-Border Insolvency In stark comparison to many developed economies, India hasn't adopted the UNCITRAL Model Law on Cross-Border Insolvency yet. However, cross-border insolvency workshops took place in March 2025 [27]. The Model Law covers four key elements for effective crossborder proceedings:

1. Access - Foreign creditors get direct access to domestic courts

2. Recognition - Simple procedures recognize qualifying foreign proceedings

3. Relief - Foreign proceedings receive necessary assistance

4. Cooperation - Courts coordinate across jurisdictions [28]

This framework would help India's growing corporate sector significantly. The World Bank and IMF support Model Law adoption to reduce cross-border dispute complications [1].

Materials and Methods: CIRP Process and Limitations Regulation 40A of the CIRP Regulations provides a well-laid-out framework that governs the insolvency resolution process. The regulation shows activities in what looks like a step-by-step process. Many of these activities can run simultaneously across five areas: claims, assets, finding resolution applicants, avoiding transactions, and gathering information [29]. CIRP timelines under Regulation 40A The model timeline starts when CIRP begins (T) and moves through clear stages. Public announcement happens by T+3, claim submissions by T+14 (which can extend to T+90), claim verification by T+21, CoC formation by T+23, and the first CoC meeting by T+30 [30]. The next steps include RP appointment, valuation work, preparing information memorandum (T+54), and submitting resolution plans (T+135) [31].

Recent changes have updated these timeframes to make the process faster. To name just one example, see how the expression of interest timeline moved up because information memorandums weren't needed at this early stage. The preparation time for information memorandums got longer to deal with real problems like missing documents and promoters who won't cooperate [29]. Limitations in stakeholder coordination The CIRP ecosystem often faces problems with coordinating between different participants. Resolution professionals deal with difficult corporate debtors who hold back records, refuse to hand over management, and discourage staff from helping [32]. Creditors sometimes don't participate enough in CoC meetings and put their own interests ahead of what's good for everyone [33]. Marketing distressed assets creates another big challenge.

Large CIRPs can hire professional marketing services, but smaller cases can't afford these costs. IBBI made it mandatory to develop marketing strategies for claims over ₹100 crore to get the best value from assets [29]. Impact of delays on asset value and recovery IBBI's data shows that longer resolution times lead to lower recoveries. Cases that wrap up within 330 days recover about 49. 2%, while those taking more than 600 days only get back 26. 1% [34]. Each extra day reduces asset value, makes revival less likely, and cuts into what creditors can recover. CIRP cases now take 679 days on average, way more than the 330-day legal limit [7]. These delays hit secured creditors hard, who now get back just 4% of their claims through liquidation [8]. The average resolution time has grown from 613 days in March 2023 to 858 days by December 2023, which shows this problem isn't going away [33].

Conclusion Results from the Corporate Insolvency Resolution Process under IBC 2016 show both wins and challenges. Numbers tell a positive story - 75% of cases have reached closure and financial creditors recovered an average of 32%. We have a long way to go, but we can build on this progress, especially when you have issues with timelines and protecting asset values. The process needs work in three key areas to work better. NCLT needs more benches and efficient procedures to handle its growing caseload. Stronger penalties would stop promoters from refusing to cooperate and help protect asset values. Rules that prevent operational creditors from using CIRP just to recover money would keep the system's integrity intact. Looking at systems from other countries could make India's insolvency process stronger.

The US Chapter 11's approach lets debtors stay in charge, which helps companies file early and keep running. The UK's system gave an explanation about protecting everyone's interests fairly. On top of that, using the UNCITRAL Model Law would help India handle cross-border cases better. Supreme Court decisions in Swiss Ribbons, Essar Steel, and Jaypee Infratech cases have shaped how CIRP works. These rulings are the foundations of stakeholder rights and CoC's authority. Regular changes to laws show the system adapts to what the market needs. CIRP works nowhere near perfectly, but it's much better than old insolvency systems. Success rates jumped from 21% to 61% between 2017 and 2024. This soaring win shows that with focused improvements and court guidance, CIRP can meet its main goal - solving cases quickly and getting the best value for everyone involved.

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