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INTERNATIONAL
JOURNAL FOR LEGAL
RESEARCH & ANALYSIS
(ISSN 2582 – 6433)
VOLUME 2 ISSUE I
(April 2021)
Email –
editor@ijlra.com
Website – www.ijlra.com
5656565656565
1
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Volume 2 Issue I| April 2021 ISSN: 2582-6433
DISCLAIMER
No part of this publication may be reproduced or copied in any form by any means
without prior written permission of Managing Editor of IJLRA. The views
expressed in this publication are purely personal opinions of the authors and do not
reflect the views of the Editorial Team of IJLRA.
Though every effort has been made to ensure that the information in Volume I
Issue X is accurate and appropriately cited/referenced, neither the Editorial Board
nor IJLRA shall be held liable or responsible in any manner whatsever for any
consequences for any action taken by anyone on the basis of information in the
Journal.
Copyright © International Journal for Legal Research & Analysis
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Volume 2 Issue I| April 2021 ISSN: 2582-6433
EDITORIAL TEAM
EDITORS
Ms. Ezhiloviya S.P.
Nalsar Passout
Ms. Priya Singh
West Bengal National University of Juridical Science
Mr. Ritesh Kumar
Nalsar Passout
Mrs. Pooja Kothari
Practicing Advocate
Dr. Shweta Dhand
Assistant Professor
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Volume 2 Issue I| April 2021 ISSN: 2582-6433
ABOUT US
INTERNATIONAL JOURNAL FOR LEGAL RESEARCH & ANLAYSIS
ISSN
2582-6433 is an Online Journal is Quarterly, Peer Review, Academic Journal,
Published online, that seeks to provide an interactive platform for the
publication of Short Articles, Long Articles, Book Review, Case Comments,
Research Papers, Essay in the field of Law & Multidisciplinary issue. Our aim
is to upgrade the level of interaction and discourse about contemporary issues
of law. We are eager to become a highly cited academic publication, through
quality contributions from students, academics, professionals from the
industry, the bar and the bench. INTERNATIONAL JOURNAL FOR
LEGAL RESEARCH & ANALYSIS ISSN
2582-6433 welcomes contributions from all legal branches, as long as the
work is original, unpublished and is in consonance with the submission
guidelines.
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Volume 2 Issue I| April 2021 ISSN: 2582-6433
Paper Title – Insolvency Law During Times of COVID-19
By: Yash Singh Chouhan
Table of Contents
ABSTRACT ......................................................................................................................................... 6
INTRODUCTION ................................................................................................................................. 6
PURPOSE OF INSOLVENCY & BANKRUPTCY CODE .............................................................................. 7
IMPACT OF COVID-19 PANDEMIC ON INSOLVENCY LAW ................................................................... 8
STEPS TAKEN BY GOVERNMENT OF INDIA ..................................................................................... 8
Insolvency & Bankruptcy (Second Amendment) Act, 2020 ............................................................10
Insolvency and Bankruptcy Code (Amendment) Ordinance, 2021 .................................................11
What is pre-packed insolvency? .......................................................................................................12
CONCLUSION ...................................................................................................................................13
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Volume 2 Issue I| April 2021 ISSN: 2582-6433
Bibliography ....................................................................................................................................14
ABSTRACT
In December 2019, a virus, Sars-Cov2, originated in Wuhan, China. In a matter of a few months,
it spread its sinister wings & engulfed the whole world, forcing the World Health Organization
(WHO) to declare it a pandemic on March 11, 2020. In the ensuing 5-6 months, it wrote such a
tale of misery & devastation that there was mayhem all around. For a while, everyone thought it
would take a breather only after writing the obituary of mankind on planet earth. Not only this
since last year, God's green earth faced many other catastrophes. The world witnessed Australian
bushfire, Indonesian Floods, Volcano Eruption in the Philippines, Earthquakes in India, Turkey,
China, Iran, Russia & Philippines, Locust Swarms in East Africa & Asia, Cyclone Amphan in
India & Bangladesh, Forest Fires in Uttarakhand, Floods In Assam in India, Snow in Antarctica
Turning Green and many now the second wave of COVID-19 has made us sit up & realize the
importance of carefully planning for the unexpected events. All these unfortunate events affected
the world terribly, and the body blow was delivered by the corona pandemic. It forced most
governments to impose lockdown to stop the spread of coronavirus, which disrupted & brought
to a grinding halt almost everything under the sun, and insolvency law was not an exception. In
this paper, the author has discussed the impact of the COVID- 19 pandemic on insolvency and
bankruptcy law. Amendments brought to combat such a disastrous situation will be explored
because it would be very inhumane on the part of the Government to initiate insolvency
proceedings against corporate houses, individuals or any other business entity amidst a pandemic
where all economic activities came to a halt. The methodology opted for this study is doctrinal.
The research is mainly based on secondary sources. The secondary source of data such as
research papers, articles, and blogs by experts on Insolvency & Bankruptcy Code, 2016 has been
referred to reach a conclusion.
INTRODUCTION
One of the major reforms that the current NDA government has brought in the banking and
finance sector is the enactment of the Insolvency and Bankruptcy Code, 2016. Since
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Volume 2 Issue I| April 2021 ISSN: 2582-6433
independence and more specifically after the economic liberalization of the 90s Indian banks
sanctioned loans and lent money indiscriminately & this led to creating a high percentage of
Non-Performing Assets (NPAs). NPA can be described as a loan given in advance for which the
principal or the interest is not paid for more than ninety days. So those borrowers who haven't
paid their loan for ninety days or are not able to repay their loans are classified as NPA. This
situation was highlighted by asset quality reviewers of the Reserve Bank of India. The horrifying
numbers of NPAs prompted the Government to act swiftly & it appointed a 'Joint Committee of
Parliament on April 28, 2015 1; the committee, in its report of 2016, recommended the enactment
of the Insolvency & Bankruptcy Code, 2016.
In 2014, a committee called Bankruptcy Law Reform Committee (BLRC) under the
chairmanship of Dr T. K. Viswanathan, former Union Law Secretary, was constituted. The
committee submitted its report in November 2015 recommending enactment of the Insolvency
and Bankruptcy Code, 2016 by consolidating all the existing laws application on both non-
financial corporations and individuals.
Insolvency & Bankruptcy Code, 2016 was passed by the Lok Sabha on May 05, 2016, and by the
Rajya Sabha on May 11, 2016. It got the assent of the President of India on May 28, 2016. In
December 2016, the Insolvency and Bankruptcy Code, 2016 was made partly operational as part
III of the Code, which contains provisions regarding the bankruptcy of individuals and
partnership firms, was made operational on November 15, 2019. Insolvency and Bankruptcy
Code, 2016 was enacted with the aim of improving the relationship between creditors and
debtors. Further, on June 01, 2016, National Company Law Tribunal (NCLT) and National
Company Law Appellate Tribunal 2were set up under the Companies Act, 2013 to adjudicate the
disputes of companies and limited liability partnership arising under the Code. In the case of
individuals and partnerships, the adjudicating authority is Debt Recovery Tribunal (DRT) and
Debt Recovery Appellate Tribunal (NCLAT), which was established under Recovery of Debts
due to Banks and Financial Institutions Act, 1993.
PURPOSE OF INSOLVENCY & BANKRUPTCY CODE
As the Preamble to the IBC, 2016 states, this is "An Act to consolidate and amend the laws
relating to reorganization and insolvency resolution of corporate persons, partnership firms and
individuals in a time-bound manner for maximization of value of assets of such persons, to
promote entrepreneurship, availability of credit and balance the interests of all the stakeholders
including alteration in the order of priority of payment of Government dues and to establish an
1
All you need to know about Insolvency and Bankruptcy Code .... https://blog.ipleaders.in/all-need-know-about-
insolvency-bankruptcy-code/
2
NCLT benches to be set up at Amaravati, Indore. https://in.news.yahoo.com/nclt-benches-set-amaravati-indore-
125700613.html
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Volume 2 Issue I| April 2021 ISSN: 2582-6433
Insolvency and Bankruptcy Board of India, and for matters connected therewith or incidental
thereto.3 "
The Preamble of this can be summarized as follows -
1. To consolidate & amend the laws relating to reorganization and insolvency resolution of
the corporate person, partnership firms, and individuals.
2. In a time-bound manner.
3. For maximization of value of assets, bankrupt people.
4. Promotion of Entrepreneurship.
5. Availability of credit.
6. Balance of interest of all stakeholders, including alteration in priority of payment of
Government dues.
7. Establishment an Insolvency & Bankruptcy Board of India.
As per the press release given by Govt. of India, the primary goal behind the enactment of this
Act is to promote entrepreneurship and innovation. In Mobilox Innovations V. Kirusa 4
Software, it was observed that the Insolvency code is not intended to be a substitute for a
recovery forum. In Innoventive Industries V. ICICI Bank, it was observed that the insolvency
code is a consolidating act. It is completely exhaustive in the matters dealt with therein. It is
covered in Entry 9 list III of the Seventh Schedule 5.
IMPACT OF COVID-19 PANDEMIC ON INSOLVENCY LAW
After WHO declared the spread of COVID-19 as a pandemic, countries around the globe started
amending their insolvency laws, especially European countries, to ease the trouble of businesses.
Governments across the world understood that this worldwide lockdown caused by this
pandemic had disrupted the demand & supply chain. Governments of various countries
understood this slowdown caused by lockdown would severely affect the economy & financial
capabilities of all kinds of business entities and individuals unless some sort of relief is provided.
The situation at that time was so grave that if no relaxation was given then, it would have lead to
the insolvency of companies. Due to this catastrophe, not only the corporate debtor but the
prospective Resolution Applicants, who otherwise were interested in the revival of the stressed
companies, would have to move forward as their existing business has been badly affected by
this pandemic.
STEPS TAKEN BY GOVERNMENT OF INDIA
On March 24, 2020, the Ministry of Finance announced that the monetary threshold of default
3
THE INSOLVENCY AND BANKRUPTCY CODE, 2016 NO. 31 OF 2016.
https://ibbi.gov.in/uploads/legalframwork/76b5b16aec39d2b0e3a20c15f907f0ac.pdf
4
2018, 1 SCC 353
5
2018, 1 SCC 407
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Volume 2 Issue I| April 2021 ISSN: 2582-6433
for filing a resolution process under IBC should be increased to INR 10,000,000 from the
previous threshold amount of INR 100,000 with immediate effect. Ministry of Corporate Affairs
notified the same on the same 6 day, vide Notification No. Regd.No.D.L.-33004/99. This step of
increasing the threshold limit has a direct implication on sections 7, 9, and 10 of the Code, which
deals with the filling of the application before adjudicating authority. Now without any exception
threshold limit to contemplate the default amount has increased to INR 10,000,000. So, from
now onwards, all applications of financial creditors, operational creditors, or even by the
corporate debtor can only be entertained if the default amount is a minimum of INR 10,000,000
or more. This step was very much required for small & medium scale business enterprises
working with low capital because these sectors were badly affected by this deadly pandemic.
Now the question arises whether this notification is applicable to MSMEs or all business
entities? Well, in my plain reading of this notification, it seems that it is applicable to all types of
business entities affected by the pandemic.
Exclusion of the Lockdown Period from the timeline period of 330 days - Section 12 of the
Insolvency and Bankruptcy Code, 2016 deals with the time-limit for completion of the
insolvency resolution process, proviso of clause 3 of sec 12 states corporate insolvency process
must be mandatory be completed within three thirty days from the commencement of CIRP
including all extension granted vide notification No. IBBI/2019/20/REG059 dated 29/03/2020.
In order to exempt the lockdown period from the timeline of three thirty days, Regulation 40-C
has been inserted in the Insolvency and Bankruptcy Board of India (Resolution Process for
Corporate Persons) Regulations, 2016. The notification reads as:
"40-C. Special provision relating to timeline. — Notwithstanding the timelines contained
in these regulations, but subject to the provisions in the Code, the period of lockdown
imposed by the Central Government in the wake of the COVID19 outbreak shall not be
counted for the purposes of the timeline for any activity that could not be completed due
to such lockdown, in relation to a corporate insolvency resolution process. 7"
Hence, with the three-thirty days of CRIP will be computed, the days on which lockdown was
imposed will get excluded; only working days will be taken into consideration for computation
for CIPR.
The National Company Law Tribunal Appellate Tribunal (NCLAT) took a suo motu cognizance
of the situation on 30-03-2020. NCLAT vide order Company Appeal (AT) (Insolvency) No.01
of 2020 held that the period of lockdown imposed by the Union Government to prevent the
7
Impact of COVID-19 on Insolvency and Bankruptcy Code, 2016 .... https://ibclaw.in/impact-of-covid-19-on-
insolvency-and-bankruptcy-code-2016-reliefs-implications-by-rahul-kumar/
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Volume 2 Issue I| April 2021 ISSN: 2582-6433
spread of COVID-19 outbreak should not be counted for the purposes for computation of any
activity that could not be completed due to such lockdown, in relation to a corporate insolvency
resolution process. The relevant portion of the said order reads as follows -
“It is further ordered that any interim order/stay order passed by this Appellate Tribunal in
anyone or the other appeal under Insolvency and Bankruptcy Code, 2016 shall continue till 8the
next date of hearing, which may be notified later."
Insolvency & Bankruptcy (Second Amendment) Act, 2020
The biggest step Govt. of India took last year to provide relief to borrowers was the promulgation
of the Insolvency & Bankruptcy Amendment Ordinance 2020 on June 05, 2020. This ordinance
was later formally passed by both the houses and received the assent of the Hon'ble President on
September 23, 2020. This amendment inserted section 10A, which talks about suspension of
initiation of corporate insolvency resolution process section 10A reads as –
"Notwithstanding anything contained in sections 7, 9, and 10, no application for initiation of
corporate insolvency resolution process of a corporate debtor shall be filed, for any default
arising on or after March 25, 2020, for a period of six months or such further period, not
exceeding one year from such date, as may be notified in this behalf:
Provided that no application shall ever be filed for initiation of corporate insolvency resolution
process of a corporate debtor for the said default occurring during the said period9.
Explanation.—For the removal of doubts, it is hereby clarified that the provisions of this section
shall not apply to any default committed under the said sections before March 25, 2020."
In order to provide relief for the financial distress faced by the corporate debtors due to
coronavirus, Govt. introduced this new amendment, namely section 10A of the Insolvency and
Bankruptcy Code. Section 10A suspended Section 7, Section 9, and Section 10 of the Code,
10
2016. Sections 7, 9 & 10 deals with the initiation of the Corporate Insolvency Resolution
Process (CIRP). Suspension of these three provisions prohibited the financial creditors,
operational creditors & corporate applicants from initiating the Corporate Insolvency Resolution
Process (CIRP) for six months, but not exceeding 12 months as per the 1 st notification regarding
the suspension. Further on 17/05/2020, Hon’ble Finance Minister Mrs Nirmala Sitaraman,
through an official press conference, clarified that the insolvency & Bankruptcy Code would
remain suspended for another year, making it a complete one-year suspension from the
8
Lockdown Period To Be Excluded From Insolvency Process ....
https://www.moneycontrol.com/news/india/lockdown-period-to-be-excluded-from-insolvency-process-timeline-
nclat-5089651.html
9
Section 10A: Suspension of initiation of corporate .... https://ibclaw.in/section-10a-suspension-of-initiation-of-
corporate-insolvency-resolution-process/
10
Impact of COVID-19 on Insolvency and Bankruptcy Code, 2016 .... https://ibclaw.in/impact-of-covid-19-on-
insolvency-and-bankruptcy-code-2016-reliefs-implications-by-rahul-kumar/
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Volume 2 Issue I| April 2021 ISSN: 2582-6433
notification.
The primary goal of this amendment was to suspend section 7, 9 & 10 of the Code to protect the
borrowers from being dragged into insolvency during times of crisis. Now the question arises
what do these provisions do? Below we will understand the purpose of these three sections.
Section 7 allows a financial creditor to file for initiating the corporate insolvency resolution
11
process against a corporate debtor. Section 9 contains provision regarding the application of
insolvency by an operational creditor, and Section 10 allows initiation of insolvency proceedings
by a corporate applicant.
Further, on 17/03/2020, in a press conference, the Hon’ble Finance minister said that to provide
relief to Micro, Small & Medium Enterprises during the COVID-19 crisis, a new framework for
MSMEs will be notified under section 240A of the IBC.
This deadly pandemic has disastrously affected both the organized & unorganized sectors.
During the lockdown period economy was at an all-time low, many people lost their jobs &
sources of income and to combat this catastrophe, relief by this amendment was provided by
Government. Section 10A stated that no application for the initiation of the Corporate Insolvency
Resolution Process could be led for any defaults that have arisen on or after March 25, 2020, for
a period of 6 months which can further be extended for a year. The proviso to this has also made
it clear that no application shall be led for a corporate debtor to any defaults during the period. It
has also been clarified by explaining that section 10A would not apply to any default that has
occurred before March 25, 2020.
Through this amendment, a sub-section to section 66 has been inserted, and this sun section (3)
puts an embargo on resolution professional for filing an application under section 66(2) against
all such defaults that are covered under section 10A. It is to be noted that these two changes
12
brought by way of the ordinance were beneficial last year, and we can say the amendment
served its purpose.
Insolvency and Bankruptcy Code (Amendment) Ordinance, 2021
The suspension of the corporate insolvency resolution process, which Govt. did last year by
promulgating the Insolvency & Bankruptcy (Second Amendment) Ordinance, 2020, ended on
11
Government to extend IBC suspension by another 3 months ....
https://www.cnbctv18.com/business/government-to-extend-ibc-suspension-by-another-3-months-7008441.htm
12
IBC Laws www.ibclaw - IBC Laws - IBC Laws. https://ibclaw.in/impact-of-covid-19-on-insolvency-and-bankruptcy-
code-2016-reliefs-implications-by-rahul-kumar/?print-posts=pdf
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Volume 2 Issue I| April 2021 ISSN: 2582-6433
24/03/2021. So, Govt. of India on 04/04/2021 has promulgated Insolvency & Bankruptcy Code
(Amendment) Ordinance, 2021 to allow pre-packaged insolvency resolution process for
corporate debtors classified as micro, a small or medium enterprise under MSME Act, 2006.
What is pre-packed insolvency?
Pre-pack insolvency can be described as advance planning between the creditor and the
purchaser prior to the insolvency proceedings; under this scheme, parties decide the terms of sale
of assets and other formalities before applying to the courts/ tribunals for insolvency
proceedings13. Pre-packaged insolvency is a kind of bankruptcy procedure where a restructuring
plan is agreed upon in advance of a company declaring its insolvency 14.
The United States of America first developed the practice of pre-packaged insolvency by
enacting the Bankruptcy Reform Act of 1978. A similar practice was prevalent in countries like
UK, France, Netherlands & Germany. This ordinance states that Govt. of India can notify such
pre-packaged insolvency process defaults up to rupees one crore. The suspension of the
corporate insolvency resolution process, which Govt. did last year by promulgating the
Insolvency & Bankruptcy (Second Amendment) Ordinance, 2020, ended on 24/03/2021.
Through this ordinance, Govt. has added a new chapter in the Code, chapter IIIA to specifically
deal pre-packaged insolvency resolution process. Newly inserted section 54A talks about
corporate debtors who are eligible for the pre-packaged insolvency resolution process section
54A specifies the following conditions –
(a) That the applicant has not undergone pre-packaged insolvency resolution process or
completed corporate insolvency resolution process, as the case may be, during the period of three
years preceding the initiation date;
(b) That the applicant is not undergoing a corporate insolvency resolution process;
(c) That no order requiring it to be liquidated passed under section 33 against the applicant;
(d) That the applicant is eligible to submit a resolution plan under section 29A;
(e) That the financial creditors of the corporate debtor, not being its related parties, representing
such number and such manner as may be specified, have proposed the name of the insolvency
professional to be appointed as15 the resolution professional for conducting the pre-packaged
insolvency resolution process of the corporate debtor, and the financial creditors of the corporate
debtor, not being its related parties, Representing not less than sixty-six percent. In the value of
the financial debt due to such creditors, have approved such proposal in such form as may be
13
What, Why and How of Pre-Pack Insolvency. https://taxguru.in/corporate-law/what-pre-pack-insolvency.html
1414
https://en.wikipedia.org/wiki/Pre-packaged_insolvency
15
Centre Promulgates IBC Amendment Ordinance To Allow Pre .... https://livelaw.in/news-updates/centre-
promulgates-ibc-amendment-ordinance-pre-packaged-insolvency-process-msmes-172102
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Volume 2 Issue I| April 2021 ISSN: 2582-6433
specified: Provided that where a corporate debtor does not have any financial creditors, not being
its related parties, the proposal and approval under this clause shall be provided by such persons
as may be specified;
(f) That the majority of the directors or partners of the corporate debtor, as the case may be, have
made a declaration, in such form as may be specified, stating, inter alia, —(i)that the corporate
debtor shall file an application for initiating pre-packaged insolvency resolution process within a
definite time period not exceeding ninety days;(ii) that the pre-packaged insolvency resolution
process is not being initiated to defraud any person; and(iii) the name of the insolvency
professional proposed and approved to be appointed as the resolution professional under clause
(e);
(g) That the members of the corporate debtor have passed a special resolution, or at least three-
fourths of the total number of partners, as the case may be, of the corporate debtor have passed a
resolution, approving the filing of an application for initiating pre-packaged insolvency
resolution process.
The corporate debtor is required to obtain an approval from its financial creditors, not being its
related parties, representing not less than sixty-six percent in value of the financial debt due to
such creditors16, for the filing of an application for initiating pre-packaged insolvency resolution
process, in such form as may be specified.
Section 54D
Section 54D talks about the time frame for completion of pre-packaged insolvency resolution.
The specified time frame as per section 54D is one hundred & twenty days from the pre-
packaged insolvency commencement date.
Section 54E
Section 54E states that declaration of the moratorium and public announcement during the pre-
packaged insolvency resolution process. The moratorium shall be available from the pre-pack
commencement date till the closure of the process, whether by approval of the resolution plan or
otherwise. The corporate debtor shall remain under the control and possession of the current
promoters and management during the pre-pack process.
CONCLUSION
COVID-19 is not the first pandemic or crisis that this world is dealing with. The great human
civilization has won many terrific battles in the past. I believe that this current situation too will
also pass. In the space of insolvency and bankruptcy law, this war has many worries, for
16
Pre-packaged insolvency framework for MSMEs: Govt .... https://www.taxscan.in/pre-packaged-insolvency-
framework-for-msmes-govt-promulgates-insolvency-and-bankruptcy-code-ordinance-2021/108826/
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Volume 2 Issue I| April 2021 ISSN: 2582-6433
instance, Government, regulator, insolvency professional, insolvency professional agencies,
creditor, and debtors. As we can see that the Govt. of India has brought two amendments in the
IBC, 2016 till now, to combat the situation and provide relief to debtors; we can clearly
conclude that the concerned ministry has regularly monitored the situation. The latest ordinance
that has been promulgated on 04/04/2021 primarily focuses on providing relief to micro, small
and medium enterprises; the 2021 amendment talks about pre-packaged insolvency for MSMEs.
In the 2020 amendment, the Government excluded 'COVID-19' related debt from the definition of
default under the Insolvency and Bankruptcy Code and increases the threshold limit from Rs. 1
lakh to Rs. 1 crore, which is serving the purpose of the Government to protect the MSMEs and
Small Corporate Debtors from the insolvency proceedings under the Code. Now, as we know,
that second wave of COVID-19 has started spreading its sinister wings, and several cities are
under partial lockdown, and the rising numbers of COVID-19 are clearly telling us that if the
same situation persists for few more weeks, then in India, we are heading towards a nationwide
lockdown again. Considering this situation, if again a lockdown is imposed, then I would suggest
in order to save all types of businesses, whether small, medium and big or individual debtors
government should again suspend all insolvency proceeding for at least 365 days or for at least
a period until economy properly revives. For individual debtors who have lost their job or
source of income due to the COVID-19 crisis or who are unable to repay for them for any reason
relating to the COVID-19 crisis, the Government should introduce a special moratorium scheme
so that they get relief and get a chance to re-establish themselves.
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2. Kumar, Rahul. www.ibclaw.in. July 10 2020. March 28, 2021, .
3. Paliwal, Misha & Vaijayant. www.lawaisa.com. 2020 April 23. 30 March 2021
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4. Rajat Sethi & Tanya Ahharwal. www.mondaq.com. August 24 2020. April 02 02www.ijlra.com
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proceedings-under-the-insolvency-and-bankruptcy-code-2016#:~:text=In March-April
2020%2C regulations,completed due to such>.
5. Sahoo, Dr M.S. Insolvency Law in Times of COVID-19. 2020.
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