JURIS DAILY VERIFIED SUPREME COURT JUDGMENT ARCHIVE

Ebix Singapore Pte Ltd v. Committee of Creditors of Educomp Solutions Ltd.

⚖️ Supreme Court of India | 📅 Date: 13 September 2021 | 📜 Citation: (2022) 2 SCC 401 | 2021 INSC 468

Bench Composition: 2-Judge Bench (Dr. Justice D.Y. Chandrachud & Justice M.R. Shah)

📜 Statutory & Legislative Framework

Act / Legislation: Insolvency and Bankruptcy Code, 2016 (IBC)

Specific Statutory Provision: Section 30(4), Section 31 & Section 60(5)

❓ Core Legal Issue

Whether a Successful Resolution Applicant (SRA) can unilaterally withdraw, modify, or exit an approved Resolution Plan after approval by the Committee of Creditors (CoC).

⚖️ Binding Ratio Decidendi (Supreme Court Holding)

The Supreme Court held that once a Resolution Plan is approved by the CoC, it becomes a binding contract. A Successful Resolution Applicant cannot unilaterally withdraw, modify, or seek exit from the plan pending NCLT approval.

💡 Key Legal Principles Established

Absolute Sanctity of CoC-Approved Plans: Resolution plans approved by CoC create binding statutory obligations prohibiting bidder withdrawal or post-approval modification.