NCLT cannot entertain challenges to statutory orders passed by authorities under State Urban Planning legislation.

The Appellants are allottees of a real estate project undergoing Corporate Insolvency Resolution Process (CIRP), which commenced on 30/09/2019

A Resolution Plan was approved on 13/12/2021, which authorized the Successful Resolution Applicant (SRA) to obtain necessary approvals, including map sanctions

On 03/05/2025, the Lucknow Development Authority (LDA) sanctioned the project map under the Uttar Pradesh Urban Planning and Development Act, 1973

Aggrieved, the Appellants moved the Allahabad High Court, which directed the LDA to hear their grievances; the LDA subsequently passed an order on 03/02/2026

The Appellants then filed I.A. 189/2026 before the National Company Law Tribunal (NCLT), seeking the cancellation of the sanctioned map and directions for the SRA to seek fresh consent from allottees

The NCLT dismissed the application as "not maintainable" via an order dated 21/01/2026, leading to this appeal

1. Whether the Adjudicating Authority (NCLT) has the jurisdiction to set aside or interfere with a map sanctioned by a statutory authority acting under the Uttar Pradesh Urban Planning and Development Act, 1973

2. Whether the dispute regarding the map sanction arises "solely" out of the insolvency of the Corporate Debtor so as to fall within the NCLT’s jurisdiction as per the ratio in Gujarat Urja Vikas Nigam Ltd. vs Amit Gupta

statutory orders passed under the Uttar Pradesh Urban Planning and Development Act, 1973, must be challenged through the remedies provided within that specific Act, such as revisionary powers of the State Government

The court also applied the principle from Gujarat Urja Vikas Nigam Ltd. vs Amit Gupta (2021), which restricts NCLT jurisdiction to disputes that arise "solely out of and relate to the insolvency of the Corporate Debtor," rather than independent statutory actions taken by third-party authorities

The Appellants contended that the NCLT had jurisdiction because the sanctioned map allegedly violated the approved Resolution Plan and RERA requirements

However, the Tribunal observed that the LDA’s sanction on 03/05/2025 was an exercise of "Statutory jurisdiction" under state planning laws, occurring more than four years after the Resolution Plan's approval

Distinguishing the present case from Gujarat Urja, the Tribunal noted that while a contract termination based only on an insolvency trigger relates to CIRP, a map sanction by a state authority under urban planning laws is an independent administrative act

Consequently, the NCLT cannot sit in judgment over the statutory decisions of the LDA, as such orders can only be challenged via the appellate or revisionary mechanisms established under the 1973 Act

It held that the NCLT did not commit an error in rejecting the application as "not maintainable" because it lacked the authority to cancel a map sanctioned under the Uttar Pradesh Urban Planning and Development Act, 1973

The Appellants were granted liberty to seek appropriate remedies under the 1973 Act against the LDA's order