Lifting Of Corporate Veil and Group Insolvency

 

The creditors might have given loan to a company based on the credentials of the group, and the management might have siphoned the funds into related entities, causing insolvency of the borrower company. In such a situation, the creditors of the borrower insolvent company will suffer huge financial loss. Further, in some cases, there may be practical difficulties in carrying out the insolvency proceedings of one or more entity within a group due to intermingling of assets of the group entities. There is, therefore, a need to carve an exception to the concept of separate legal entity, and pierce the corporate veil by bringing the assets of the solvent entities within the purview of the insolvency proceedings of its associate or subsidiary.

 

In India, the concept of group insolvency gained prominence in the case of Videocon Industries Limited[1], wherein the Hon’ble National Company Law Tribunal, Mumbai Bench held that in the corporate insolvency resolution process of Videocon Industries Limited, the assets of the entire Videocon Group, including any assets held by the foreign subsidiary, will be considered to a part of the property of Videocon Industries Limited. Thereafter, the Insolvency and Bankruptcy Board of India constituted a working group to develop a draft framework on group insolvency.

 

The working group has submitted its report highlighting the key concerns and has also provided recommendations on the same, however, the insolvency law has still not incorporated separate provisions for group insolvency. In this paper, the author has tried to gain insights from the legislations and rulings in other jurisdictions, analysed the various factors which can be considered in piercing the veil in group relationships, and attempted to evaluate how the same can be adapted in the Indian context.

 

Introduction:

As a general rule, every company has a separate legal personality, however, there may be situations where the fate of two or more companies are linked to each other. For instance, it is common business practice for group entities to regularly engage in related party transactions such as cross collateralisation, guarantee comforts, tunnelling or significant influence arrangements. While such structures largely respect the separate legal status of the group companies, practice suggests such inter-linkages in business, operations and management often raise significant challenges when any one or more entity in the group become insolvent[2].

Business entities having complicated organisational structures, with network of subsidiaries and investment vehicles, leads to convoluted insolvency problems. Considering this situation, certain difficulties arise in adjudicating the company's insolvency through bankruptcy proceedings, the resultant resolution of insolvency through liquidation of properties/assets and distribution of the proceeds thereof to the various creditors and contributors. Further, fraudulent practices of insolvent debtors such as concealing or transferring assets to group companies, has aggravated, both in terms of frequency and magnitude[3]. Other problems include selection of forum and conflict of debtor and creditor rights. In these kind of instances, for value maximisation on behalf of the stakeholders and for a successful resolution, lenders request consolidation. With reference to the insolvency law, it is understood that courts generally lift the corporate veil where one company in the group could be held liable for the debts of the other company/ies or if a group of companies functioned collectively[4].

All- inclusive approach would level out the losses or inequitable gains that occur to lenders. Nevertheless, reorganizing assets for rehabilitation of company might not always be a viable option. Internationally, legal systems have been thriving to developed laws to handle the consequences of business failures, including an orderly and equitable distribution of the assets left to the failed business creditors.[5] As far as India is concerned, it has recently adopted the Insolvency and Bankruptcy Code, 2016 (IBC) with a view to provide an effective framework for conduct of insolvency proceedings. However, it is difficult to say whether the legislation stands effective without having considered the inevitable aspect of group insolvency.

In this paper, the author has analysed the existing legal framework dealing with this issue, the emerging trends and problems faced due to insufficiency of laws in India.  Further, after a study of the scenario abroad, an attempt has been made to provide a solution to the current situation.


Legal Landscape of India:

Legislative Framework:

With the aim to promote the principles of a social, economic and political justice enshrined in the Preamble to the Indian Constitution, the state strives to provide an effective system for dispensation of justice. As far as insolvency resolution is concerned, the Indian Constitution empowered both the Parliament and State Legislature to enact laws relating to bankruptcy and Insolvency.[6] Consequently, a number of overlapping legislative acts and regulations on this subject made the insolvency, liquidation and reorganisation process not only very chaotic but led to delays and conflicts between these various laws and legal forum.[7]

The current legal framework does not provide for a comprehensive policy in resolving group insolvency matters. Though the revamping has been initiated with introduction of IBC in 2016, which provides for restructuring a company undergoing insolvency proceedings, in a time bound manner, rather than having focus on liquidation. Additionally with the assistance of insolvency professionals, by bringing in investors and the support of consulting creditors, a resolution plan is formulated and negotiated upon. Finally, a legally compliant plan is approved and implemented in accordance with IBC. But the law is practically silent on group insolvency issues. Therefore, this chapter focuses on the existing laws in India and how they have been rather irrelevant in comprehending the intricacies of group insolvency.

Group Insolvency in India:

Before proceeding to the landscape of the insolvency laws in India, it is pertinent to understand their origin. The century old statues i.e. the Presidency Town Insolvency Act 1909 and the Provincial Insolvency Act 1920 are the two statues that are still dealing with insolvency of individuals or partnerships. Enacted over a century ago, under the British regime, these are severely out dated laws and consequently inadequate to address the emerging complications of group insolvency.

Post-independence, the economic and political landscape led to phenomenal lending at subsidised rates to boost industrial development, thereby lacking focus on efficient bankruptcy system.[8] 

The Industries Development and Regulation Act of India, 1951 empowered Central Government to take over the control and management of the companies in liquidation.[9] This Act was much before privatization policy, therefore, liquidation proceedings aligned with the primary objective of the Act i.e. policy of industrial licensing and government control.

Eventually the Companies Act was enacted in 1956 (“1956 Act”), which provided for three categories of proceedings for winding up a company- (i) voluntarily winding up; (ii) compulsory winding up; (iii) winding up subject to court supervision. Section 433 of the 1956 Act clearly stipulated that a company that is unable to fulfil its obligations towards outstanding debts maybe wound up by the Court or Tribunal.

Thereafter, the revival and rehabilitation of sick companies was attempted under the Sick Industrial Companies (Special Provisions) Act, 1985, which though was the central law governing corporate rescue but it was only applicable to industrial companies. This law also did not comprehend the need to address any issue regarding group insolvency.

In the Debt Recovery Tribunals under the Recovery of Debts Due to Banks and Financial Institutions Act of 1993 also, the focal point remained recovery of debts due to banks and financial institutions. Therefore, individuals and corporations could not obtain any relief under this statute.[10] This statue had another glaring issue. The applications under this law could only be made by creditors and not by special purpose vehicles for securitization, designed to save the company through additional investments, resulting in the application of traditional but time-consuming methods of foreclosure to these entities.[11]

Faster economic growth also triggered an increase in bad loans and non-performing assets, and in 2002, the government introduced the Securitization and Reconstruction of Financial Assets and Enforcement of Security Interest Act to authorize secured creditors to enforce receivable loans by attaching or selling security, without court intervention[12]. However, this was merely a debt recovery procedure rather than a solution to insolvency[13] let alone group insolvency.

Even the Companies (Amendment) Act, 2002 did not incorporate the suggestions of Justice Eradi Committee with regard to adoption of Model Law. [14]  The position was not altered much, with respect to group winding up, even after introduction of Companies Act 2013.

In view thereof, India was in dire need to revamp its insolvency law in order to come at par with the international standards.


Advent of IBC: 

Finally, IBC paved way for a comprehensive liquidation and reorganisation process in India. Interestingly, when the Bill was first introduced in Lok Sabha in 2015, the issue of group insolvency was not even addressed.

 

Landmark Cases: 

Judicial Gap Filling:

While a formal legislation on group insolvency is yet to be formulated, however, in several matters, National Company Law Tribunal has taken cognizance of the functioning pattern of group entities while determining group insolvency issues. This chapter seeks to analyse, through elaborate discussion of case laws, the judicial filling of this absent legislation in India and the impact thereof.


Jurisdiction of Indian Courts in Insolvency/ Liquidation Proceedings: 

Following were some instances where the Indian judiciary lifted the corporate veil in insolvency of an entity, where it was seen that the corporate debtor is only a shell company and did not have any assets or net worth for the creditors to recover their dues, or there was no likelihood for any resolution applicant to submit any resolution plan, or there was high possibility that insolvency/ liquidation of corporate debtor might reach a dead end.

 

i) In the insolvency process of Videocon Industries Limited, the assets of the entire Videocon Group, including those held by its foreign subsidiaries, were considered to be a part of Videocon Industries Limited[15].

 

ii) Supreme Court held as follows:

“where a statute itself lifts the corporate veil, or where protection of public interest is of paramount importance, or where a company has been formed to evade obligations imposed by the Law,  the court will disregard the corporate veil. Further, this principle is applied even to group companies, so that one is able to look at the economic entity of the group as a whole….the Court may pierce the corporate veil for the purpose and only for the purpose of depriving company or its controller of the advantage that they would otherwise have obtained by company’s separate legal personality”[16].

 

(iii)    NCLT, Mumbai consolidated the insolvency processes of Lavasa Group, observing that since the subsidiary companies are financially dependent on the holding company, the insolvency process of subsidiary companies are also by far dependent on the insolvency process of the holding company[17].

(iv) In Bikram Chatterji vs. Union of India[18], the Supreme Court froze the bank accounts of the holding entity.

(v) In Chitra Sharma vs. Union of India[19], the Supreme Court directed the parent company to deposit money, and also attached its assets.

(vi)  In Edelweiss Asset Reconstruction Company Limited vs. Sachet Infrastructure Pvt Ltd.[20], since several group entities where working to develop a common township, the National Company Law Appellate Tribunal consolidated their insolvency process for the benefit of the homebuyers.

(vii)  In Sanghvi Motors Limited vs. Albanna Engineering (India) Pvt. Ltd.[21], NCLT, Kochi directed invocation of bank guarantees provided by the parent of the debtor company.


Unresolved and Beyond Judicial Reach:

Indian courts have adopted a rather progressive attitude while dealing with cases involving group companies. But however there are certain practical issues that remain unresolved and beyond judicial authority of India in absence of strong legislative backing. For instance, in case of group insolvency of companies involving foreign associates/ subsidiaries/ holding companies, giving example of assets of Videocon Oil Ventures Ltd. which are located in Brazil, Indonesia and East Timor, it can be said that there is glaring incompetency in the existing regime. Gaps in the legislation not only question its efficacy but also doubts whether the resolution plans would work if profit making assets are hived off the business by the indebted debtor.

 

Precedents Abroad: 

When a company goes into insolvency, it is required to pay off its debts by way of selling its assets or similar methods, however, if the assets of the company are insufficient to meet all the claims, in several instances, the courts have pooled in the assets of related/ associated/ group companies. One might also contend that one entity may be held accountable for the liability of another entity considering the fiduciary relationship that exists between the companies, especially in the case of holding- subsidiary. In case the subsidiary entity is adjudged insolvent and it is proved that the parent entity had information of the same, or if the parent entity is company was aware or reasonably believed to have known about the same, the said parent entity may also be held accountable for the claims made against the subsidiary[22]. To gain a better perspective on the working of the group insolvency, this chapter seeks to analyse the implementation and enforcement of group insolvency law in other jurisdictions.

 

UNCITRAL Legislative Guide on Insolvency Law:

The UNCITRAL Legislative Guide provides for extension of liabilities and contribution orders. It stipulates different circumstances in which liability might be extended:

(i)  Exploitation or abuse by one group member of its control over another group member, including operating that group member continually at a loss in the interests of the parent;

 

(ii) Operation of a group member as the parent’s agent, trustee or partner[23].

 

The UNCITRAL Legislative Guide, however, further stipulates as follows:

 

“98. Generally, the mere incidence of control or domination of a group member by another group member, or other form of close economic integration within an enterprise group, is not regarded as sufficient reason to justify disregarding the separate legal personality of each group member and piercing the corporate veil.[24]


Relevant Case Laws:

The carve out from the concept of separate legal entity as envisaged in the Solomon case should not be done as a general principle, and the judiciary will have to look into several factors, analysing the facts of the case at hand, to deviate from the doctrine. In Woolfson vs. Strathclyde Regional Council[25], it was held that the veil of incorporation would be upheld unless it was a façade[26].

 

In Re a Company (1985), the Court of Appeal stated:

“In our view the cases before and after Wallersteiner vs. Moir (1974) 1 WLR 991 show that court will use its power to pierce the corporate veil if it is necessary to achieve justice irrespective of the legal efficacy of the corporate structure under consideration[27].”

 

This was the landmark case wherein the court intervened and held that while generally each of the companies have a distinct identity, the same should not serve as a constraint on justice.

 

In Limpus vs. London General Omnibus Co. Ltd.[28], the following factors were laid down for considering piercing of veil in subsidiary and group relationships:

(i) The personnel deployed by holding company and its subsidiaries and are distinct and the parent company has no power to decide on the appointment/ termination of any employees of the daughter entity;

(ii)  The holding company has not given any corporate guarantee or has not pledged any of its properties, for the debts availed by its subsidiaries;

(iii) The equipment and other goods of the parent and subsidiary are separate;

(iv) The two companies do not exchange assets or liabilities;

(v)  There exists no exclusive dealing arrangement or any similar contract between the parent and daughter entity;

(vi) The holding company is not a supervisor to the operations of its subsidiaries;

(vii) The holding company has no special or distinguished power by which it can control or undertake significant commercial matters of its subsidiaries;

(viii)  The functional/ operational areas for the holding company and its subsidiaries is distinct, and not similar.

 

Where Two or More Entities Function as Single Economic Entity:

On several occasions, the courts have pierced the veil between companies in a group on the basis that, while legally distinct, economically they exist as one single, interdependent unit. Where Company A not only owns controlling interest in Company B, but is also involved in the operations of Company B, such that the companies ceased to represent separate enterprises and have become more or less indistinguishable from the larger enterprise.

In DHN food distributors’ Ltd vs. Tower Hamlets LBC[29], the veil between three companies in a group was pierced for fair and equitable purposes.

 

Fiduciary Duty of Parent Towards Subsidiary:

In Cape vs. Chandler[30], the Court of Appeal held that a parent company has a direct duty of care towards its subsidiary. The court further held that in appropriate circumstances, law may impose on a parent responsibility for its subsidiary.

In United States vs. Best Foods[31], the US Supreme Court, succinctly restated the law and provided much needed direction for anticipating parent-subsidiary liability. Accordingly, mere involvement in subsidiary’s general affairs will not make a parent company liable for breaches of subsidiaries, subject to two exceptions:

(i)  If the legal structure has been abused, consequent to which, the subsidiary has been left with insufficient funds, thereby depriving the creditors of their money (creditor protection);

(ii)  If the holding company was actively involved in running the business of its subsidiaries, such that the insolvency of the subsidiaries can be attributable to the holding company.

Again, in United States v. Kayser-Roth Corporation[32], the United States Court specifically ruled that where the parent company exercised pervasive control over its subsidiaries, the former can be accountable for the acts of the latter.

In Pauley Petroleum Inc. vs. Cont'l Oil Co.[33], the court asserted that separate entities of parent and subsidiary may be disregarded if there is proper showing of fraud, public wrong or in interest of justice.

 

Alter Ego Or Fraudulent Conduct:

When the conception of a corporate entity is employed to defraud creditors, to evade an existing obligation, to circumvent a statute, to achieve a perpetual monopoly, or to protect knavery or crime, the courts will draw aside the web of entity, will regard the corporate company as an association of live, up-and doing, men and woman shareholders, and will do justice between real persons[34].

In Harper vs. Del. Valley Broadcasters, Inc.[35] , it was held that the purpose of allowing the corporate veil to be pieced on an alter ego theory is to hold the party actually responsible for the inequitable conduct accountable and to prevent that corporation from using another corporation to shield itself from liability[36]. [See also Official Comm. of Unsecured Creditors of Sunbeam Corp. vs. Morgan Stanley & Co, Inc. (In re Sunbeam Corp.)[37]]

In Geyer vs. Ingersoll Publ'n Co.[38], it was held that court can pierce the corporate veil of an entity where there is fraud or where a subsidiary is a mere instrumentality or alter ego of its owner[39].

In Morris vs. NYS Dep't of Taxation and Fin.[40], it was observed that piercing the corporate veil requires a showing that:

(i)  owners exercised complete domination over the corporation in respect to transaction attacked; and

(ii)  that such domination was used to commit fraud or wrong against plaintiff which resulted in plaintiff's injury[41].

 

Indian Perspective:

Fortunately, India has already taken the first step to reform the insolvency system. In this chapter, an attempt has been made to dissect the draft and analyse the recommendations suggested in the report of the Working Group on Group Insolvency[42].

 

Identification of ‘Group’:

The Working Group has suggested “a ‘corporate group’ may include holding, subsidiary and associate companies, as defined under the Companies Act, 2013. However, an application may be made to the Adjudicating Authority to include companies that are so intrinsically linked as to form part of a ‘group’ in commercial understanding, but are not covered by the definition of corporate group above, as well”.

 

The Working Group has further suggested that for now, the focus will only be on domestic entities, however, in the era of rapid globalization, entities transact throughout the globe, and therefore, exclusion of foreign companies might be a drawback. Group insolvency framework backed by a cross-border insolvency framework is the need of the hour.

 

Approach of Group Insolvency: 

(i) Procedural coordination wherein the focus shall be on harmonising and synchronising the insolvency processes of multiple entities in a group, without pooling together the properties held by each entity;

(ii) Substantive consolidation wherein the assets and liabilities of companies in a group will be consolidated, such that they are treated as a single entity;

(iii)Rules dealing with perverse behaviour of companies in corporate groups wherein if the insolvency entity had entered into any preferential, undervalued, extortionate or fraudulent transactions, the  assets which have been parted with by way of such avoidance transactions will be repossessed, and the related undertakings will be held accountable for the liabilities of each other.

 

The Working Group has recommended that while (i) aforementioned may apply on all insolvent entities against whom insolvency resolution process have been initiated, however, (iii) shall apply even if an entity is solvent.

 

Mechanics for Group Insolvency: 

(i) Unified petitions: A unified/ joint petition may be filed by creditors (financial as well as operational) or corporate debtors to initiate insolvency resolution process for multiple entities. This significantly reduces the cost as compared to litigation expenses incurred if separate petitions are filed for each entity. Further, if the insolvency petition is admitted, the NCLT may order that a unified public announcement be published with respect to the group entities. 

There may be, however, certain drawbacks in case of joint petitions, which may have to be considered while formulating the group insolvency law. For instance, one or more creditor may not agree on filing a joint petition. To resolve this, a percentage threshold may have to be fixed for moving a joint petition, wherein, if say, 66% creditors agree, a joint petition may be filed.

Also, it is relevant to understand what will be relief that may be granted in case of a petition for initiation of group insolvency, i.e. can the adjudicating authority admit the petition against any one company, while disposing off the petition against other companies in a group or the petition has to admitted/ dismissed in its entirety only. In the author’s opinion, both the options should be included as part of the relief while preparing the petition.

(ii)  One forum for adjudication of all disputes: With respect to adjudication of group entities, the Working Group has laid down the following:

(a) To save judicial time, and to bring down the cost involved in pursuing separate litigation proceedings for separate entities, the Working Group has suggested that multiplicity of jurisdictions should be avoided.

(b) In case, insolvency proceeding against one entity of a group has been admitted prior to admission of insolvency of other entities in the same group, the adjudicating authority which has first admitted the insolvency might take up the applications with respect to other entities in the group as well. 

(c)  If circumstances warrant that separate adjudicating authorities should cater to the insolvency of separate entities, then all the adjudicating authorities should share data, coordinate and communicate with one another.

(iii)   Single resolution professional for group entities: The Working Group suggests that a common insolvency professional might take care of the insolvency proceedings of all the entities in the group. However, if the said insolvency professional is unable to cater to the needs of all the entities, may be due to lack of adequate resources or otherwise, then separate insolvency professionals might be appointed for separate entities, however, all the insolvency professionals should communicate, collaborate and share data with one another.

Separate insolvency professionals for separate companies may prove to be fatal since there will be discretion on sharing of information, and one insolvency professional may limit his communication with the other insolvency professionals, especially when there are chances of intra group litigation, which may be impair the value of the entity under his control[43]. Therefore, in the author’s view, appointment of single resolution professional should be the first priority to avoid any possible conflict of interest.

(iv)  Unified meeting of the creditors: The Working Group suggests that if the creditors of the entities may decide to form a common committee of creditors to facilitate better coordination amongst themselves. The said understanding/ arrangement between the creditors, including terms relating to who shall bear the expenses of the group creditors’ committee, mechanics to exit from the group procedures, etc, may be agreed in a framework agreement. The Working Group has endowed upon the creditors the power and responsibility to decide the level of coordination that they are willing to do with each other.

(v) Subordination of claims of related entities: The Working Group suggests that virtue of an order, the adjudicating authority may subordinate related party claims to that of others, in case of fraud or diversion of funds. However, such subordination should be applied only as an exemption to the general rule, where solid proof of wrongdoing has been submitted before the adjudicating authority. 

We already have one case law in India, wherein the Hon’ble NCLT, Allahabad Bench[44] observed that a related party claim ought to rank below other claims, and held that the related party creditors be treated as equity shareholders for the purpose of determining the distribution priority during the insolvency process[45], however, a specific guideline as to when, how and under what circumstance subordination should be done will be useful.

(vi) Extension of liability: Working Group also talks about contribution orders, whereby liability may be extended on parent entities or its officers. From the Indian insolvency context, in case there are any avoidable transactions, the general relief that is being granted is reversal of such transactions, or the relevant parties are being asked to compensate the creditors for the loss suffered by them. The Working Group has stipulated that IBC already has relevant provisions with respect to avoidance transactions, and therefore, no further provision with respect to extension of liability or contribution order is required. It has, however, failed to consider that the consolidation of group entities might be an advanced relief which may be sought by the creditors in case an application against avoidable transactions is being filed. Further, if after the initiation of insolvency process of one entity, there seems to be plausible reasons that the holding company was aware of or was responsible for the said situation of the debtor company, then also the creditors should have an option of pooling in the assets of the holding company. More so, if the initial loan disbursal was made by evaluating the group as a whole. It seems that the Working Group has not considered such instances, and has restricted its approach to the UNICTRAL Law, which was devised long back in 2005.

The draft framework requires much more clarity before it can be adopted into a formal legislations. While the Working Group has made a comparison with other jurisdictions to understand the impact, recommendations have stipulated certain modifications to the complete adoption of UNICTRAL Law, such as wide discretion has been given to committee of creditors to decide whether they want to go for procedural coordination or substantive consolidation. India must not stretch the modifications so as to defeat the purpose of adopting UNICTRAL Law.

 

Conclusion:

It has been established from the discussions above that Indian framework is a chaos in terms of predictability. On the other hand, it is also important to acknowledge and address the situation of growing non-performing assets in India. While a number of high ticket companies have been swept into the insolvency storm started under IBC, the allegations of financial irregularities, fraud and diversion of funds have been pouring in. Also, the number of cases filed for group insolvencies are relatively less at this point. While adopting an entirely new regime which directly impacts the authority of courts may not be an easy transition. Especially considering the peculiarities of Indian society, which treats their traditions with utmost sanctity, resistance is bound to occur. However, it must be appreciated that adoption of group insolvency is an opportunity for India to revamp its insolvency laws to pace up to international standards.

In the current scenario, the conflict still lingers and confusion persist, and therefore, concrete steps should be taken to revolutionise group insolvency laws, and only then can the motivating factors of uniformity and predictability truly come to fruition.

Summarising from the precedents discussed, in Indian context, the following indicative factors may be helpful in determining whether the case is fit for group insolvency or not:

(i)   There are several instances where the resources, including human resources, is being shared amongst group entities. For example, it is common for group entities to appoint a group legal personnel or a common accountant. It is also common to have a shared registered office amongst group entities. However, in case the cost is not distributed evenly between the entities making use of such resources, and is being accounted in books of any one entity, the same may drain the resources of the latter entity, which may consequentially impact the creditors of the said entity. In such cases, courts should not shy away from lifting the corporate veil.

(ii) There may also be instances of intra group dealings, or business linkages between two or more entities. For example, a company’s final product may be used by its group company as raw material, however, it is to be seen that an entity is not functioning as a puppet in hands of the other. Further, if the companies engage in any fraudulent practice to keep its assets beyond the reach of the creditors, whether by making priority payment to the group company in the garb of “ordinary course of business” or otherwise, the “unclean hands” doctrine will apply.

(iii)  Again, in case there are instances of diversion of funds from one entity to another, the veil may be lifted. This may occur in various ways. On such example is when there is a hypothetical book entry showing that a loan or advance has been given by one entity to the other, and then actual transfer of money from the latter entity to the former for the supposed repayment.

(iv) If there are common shareholders or directors in two entities, considering the functioning of the entities, it may be contended that one of the entity is a sham, and is merely functioning to defeat the provisions of law.


[1]State Bank of India vs. Videocon Industries Limited 2018 SCC OnLine NCLT 13182.

[2] Richa Saraf, ‘Videocon Ruling: Setting a Benchmark for Group Insolvency’ (Vinod Kothari Consultants, 28 February 2020) <https://vinodkothari.com/2020/02/videocon-ruling-group-insolvency/> accessed 28 December 2021.

[3] United Nations Commission on International Trade Law- Legislative Guide on Insolvency Law 2005 <https://uncitral.un.org/sites/uncitral.un.org/files/media-documents/uncitral/en/05-80722_ebook.pdf> accessed 28 December 2021.

[4] Ian M Ramsay, ‘Holding Company Liability for the Debts of an Insolvent Subsidiary: A Law and Economics Perspective’ (1994) 17(2) UNSW Law Journal 520-545 <https://www.unswlawjournal.unsw.edu.au/wp-content/uploads/2017/09/17-2-10.pdf> accessed 28 December 2021.

[5] Philip R Wood, Principles of International Insolvency (2nd Ed, Sweet & Maxwell, 2007).

[6] ‘Bankruptcy and Insolvency’ is an item specified in Entry 9, List III of the Constitution of India. List I, Entry 43 provides ‘incorporation, regulation and winding up of trading corporations, including banking, insurance and financial corporations, but not including co-operative societies’ and Entry 44 stipulates ‘incorporation, regulation and winding up of corporations, whether trading or not, with objects not confined to one State, but not including universities.’ State can under, List II, Entry 32, enact laws relating to ‘incorporation, regulation and winding up of corporations, other than those specified in List I…’

[7] Paul J. Omar, ‘Landscape of International Insolvency Law’ (2002) 11 Int. Insolv. Rev. 173-200 <https://www.iiiglobal.org/sites/default/files/landscapeofinternationalinsolvencylaw.pdf> accessed 28 December 2021.

[8] Nimrit Kang & Nitin Nayar, ‘The Evolution of Corporate Bankruptcy Law in India’ ICRA Bull.: Money and Fin. (October 2003) at 37, 38.

[9] IDR Act, S 18FA, provides for Central Government to take charge of companies under liquidation, if it is of opinion that such company could be revived.

[10] Ministry of Finance, Interim Report of the Bankruptcy Law Reform Committee (February 2015) recommends that the Model law should be adopted only after understanding its effectiveness in India. Also, suggests that other alternative approaches such as the EC Regulation on Insolvency Proceedings, American Law Institute’s NAFTA Transnational Insolvency Project and the International Bar Association Cross-Border Insolvency Concord should be considered <https://www.finmin.nic.in/sites/default/files/Interim_Report_BLRC_0.pdf> accessed 28 December 2021.

[11] Nidhi Shetye, ‘International Insolvency: An Indian Perspective on Cross-Border Treatment of Cases’ (2016) 39 Fordham Int’l L.J. 1045, 1050 <https://ir.lawnet.fordham.edu/ilj/vol39/iss4/3/> accessed 28 December 2021.

[12] Transcore vs. Union of India 2006 (12) scale 585, the Supreme Court upheld the concept of complete autonomy of specified creditors and lenders for classification of asset and recovery of outstanding dues.

[13] Ibid see note 21, See Nidhi Shetye at p. 1045.

[14] Justice Eradi Committee, Report of the High Level Committee, Law Relating to Insolvency and Winding up of Companies (2000) para 7.9 <http://reports.mca.gov.in/Reports/24-Eradi%20committee%20report%20of%20the%20high%20level%20committee%20on%20law%20relating%20to%20insolvency%20&%20winding%20up%20of%20Companies,%202000.pdf> accessed 28 December 2021.     

[15] Ibid see note 1. 

[16] Arcelor Mittal India (P) Ltd. vs. Satish Kumar Gupta (2019) 2 SCC 1.

[17] Axis Bank Limited vs. Lavasa Corporation Limited. C.P.(IB)-1765, 1757 & 574/MB/2018, 26 February 2020 <http://www.lavasa.com/pdf/Lavasa-Corporation-Limited-MA-3664-2019-in-CP-1765-1757&574-2018-NCLT-ON-26.02.2020.pdf> accessed 31 October 2021.

[18] 2021 Latest Caselaw 259 SC

[19] Writ Petition(s)(Civil) No(s).744/2017, 11 September 2017 <https://indiankanoon.org/doc/118903856/> accessed 31 October 2021.

[20] Company Appeal (AT) (Insolvency) No. 377/ 2019, 20 September 2019 <https://ibbi.gov.in/uploads/order/e43157f60f13a1679d4efb03b8d3a908.pdf> accessed 31 October 2021.

[21] MA/ 25/ KOB/ 2020, 20 April 2020; Order was later set aside in appeal; Albanna Engineering Llc vs. Sanghvi Movers Ltd. Company Appeal (AT) (Insolvency) No. 481 of 2020, 17 March 2021 <https://nclat.nic.in/Useradmin/upload/4593551946051f241c9fe6.pdf> accessed 31 October 2021.

[22] Australian Corporations Act 2001, S 588V, 588W

[23] Ibid see note 3.

[24] Ibid.

[25] (1978) UKHL 5

[26] Natasha Danielle Paxton Smith, ‘Veils, Frauds, and Fast Cars- Looking Beyond The Fixation On Piercing To The Illusory Protection Provided By Incorporation’, A dissertation submitted in partial fulfilment of the degree of Bachelor of Laws (Honours) at the University of Otago, Dunedin (October 2013) <https://www.otago.ac.nz/law/research/journals/otago065269.pdf> accessed 28 December 2021.

[27] Ibid.

[28] (1862) 1 H&C 526

[29] (1976) 1WLR 852

[30] (2012) EWCA CV. 525 CA

[31] 524, F. Supp. 842, 54 USLW 2586

[32] 20 ELR 20349.No. 88 – 0325B. 724 F. Supp. 15/301 ERC 2001

[33] 239 A.2d 629, 633 (Del. 1968)

[34] Maurice Wormser, ‘Piercing the Corporate Veil of Corporate Entity’ (1912) 12 Colum. L. Rev. 496, 517 <https://archive.org/details/jstor-1110931/page/n3/mode/2up> accessed 28 December 2021.

[35] 743 F. Supp 1076, 1085 (D. Del. 1990)

[36] Timothy E. Graulich, ‘Substantive Consolidation- A Post-Modern Trend’ (2006) 14 Am. Bankr. Inst. L. Rev. 527 <https://www.davispolk.com/sites/default/files/files/Publication/0410d3a6-774c-460c-b8c0-1b41c3fd13ca/Preview/PublicationAttachment/3ab385c3-f706-4cd6-a6ad-c8c293988b28/graulich.substantive.consolidation.article.may10.pdf> accessed 28 December 2021.

[37] 284 B.R. 355, 365 (Bankr. S.D.N.Y. 2002)

[38] 621 A.2d 784, 793 (Del. Ch. 1992)

[39] Ibid see note 39

[40] 623 N.E.2d 1157, 1161 (N.Y. 1993)

[41] Ibid see note 39.

[42] Insolvency and Bankruptcy Board of India, ‘Report of the Working Group on Group Insolvency’ (23 September 2019) <https://www.ibbi.gov.in/uploads/whatsnew/2019-10-12-004043-ep0vq-d2b41342411e65d9558a8c0d8bb6c666.pdf> accessed 28 December 2021.

[43] Ilya Kokorin, ‘Conflicts of interest, intra-group financing and procedural coordination of group insolvencies’ (2020) 29 Int Insolv Rev. 32-60 <https://onlinelibrary.wiley.com/doi/epdf/10.1002/iir.1370> accessed 28 December 2021. 

[44] J.R. Agro Industries P. Limited v. Swadisht Oils P. Ltd. C.A No. 59/ 2018, 24 July 2018 <https://ibbi.gov.in/webadmin/pdf/order/2018/Jul/24th%20Jul%202018%20in%20the%20matter%20of%20Swadisht%20Oils%20Pvt.%20Ltd.%20(J.R.%20Agro%20Industries%20P%20Ltd.%20Vs.%20Swadisht%20Oils%20Pvt.%20Ltd.)_2018-07-27%2017:16:08.pdf> accessed 28 December 2021.

[45] Richa Saraf, ‘Concept of Related Party: Interpretation by Letter or Spirit of the IBC?’ (India Corp Law Blog, 11 August 2018) <https://indiacorplaw.in/2018/08/concept-related-party-interpretation-letter-spirit-ibc.html> accessed 28 December 2021.

 

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