Claims filed less than seven days before a COOC meeting are hit by CIRP Regulation 13(1B).

The Corporate Debtor (Chandigarh Overseas Pvt. Ltd.) was admitted into Corporate Insolvency Resolution Process (CIRP) on 27.02.2023, and a public announcement for claims was made on 07.07.2023

The Appellant-homebuyer submitted a claim of ₹10,30,528/- on 15.03.2024, which was only four days prior to the Committee of Creditors (CoC) meeting scheduled for 19.03.2024 to vote on the resolution plan

The Resolution Professional (RP) refused to verify the claim citing regulatory bars, and the Adjudicating Authority (NCLT Chandigarh) subsequently dismissed the Appellant’s application (I.A. No. 604/2025) for admission of the claim

The Appellant contended that the debt was reflected in the Corporate Debtor’s books and that the RP failed to send individual notice under Regulation 6A

Whether the Resolution Professional committed a legal irregularity by rejecting a claim filed less than seven days before the CoC meeting for voting on the resolution plan

Whether the reflection of a debt in the books of accounts/Information Memorandum obligates the RP to admit a belated claim despite the timelines prescribed under the CIRP Regulations

The court primarily applied Regulation 13(1B) and 13(1C) of the IBBI (Insolvency Resolution Process for Corporate Persons) Regulations, 2016, which mandates that the RP shall verify claims received up to seven days before the date of the meeting of creditors for voting on the resolution plan

The court relied on the "clean slate" principle and the necessity of timelines established by the Hon’ble Supreme Court in *Essar Steel v. Satish Kumar Gupta*, *RCS Infrastructure Ltd. v. Mukul Kumar*, and *Ghanashyam Mishra and Sons Pvt. Ltd. v. Edelweiss Asset Restructuring Company Ltd.*, which hold that belated claims cannot be entertained after plan approval to ensure certainty and prevent indefinite delays in the insolvency process

The Tribunal found that the Appellant’s claim was filed 245 days after the public announcement and significantly breached the statutory "seven-day" window prescribed in Regulation 13(1B)

It rejected the Appellant’s reliance on *Rahul Jain* and *Sonia Kapoor* precedents, noting those cases were decided prior to the 18.09.2023 amendment which introduced the strict seven-day cut-off in Regulations 13(1B) and 13(1C)

The Tribunal further observed that while the Appellant claimed the debt was in the records, she failed to prove that the specific amount of ₹10,30,528/- was reflected in the Information Memorandum

The court reasoned that allowing such belated claims would encourage a "spanner in the works," leading to an "endless and unceasing process" that frustrates the primary objective of the IBC—timely resolution

The Tribunal clarified that procedural timelines take precedence over individual claims once the resolution process reaches the final voting stage to maintain the integrity of the IBC

However, the court left it open for the Appellant to approach the Successful Resolution Applicant (SRA) to consider the claim on par with other similarly situated creditors within the existing plan outlay