A resolution plan that the committee of creditors had already approved, and that the NCLT Delhi bench had already sanctioned, still drew five separate appeals from parties unhappy with how the process had gone. The plan belonged to Mastana Foods Private Limited, and it was worth Rs 135.39 crore, submitted by a consortium of HR Commercials Private Limited and Crown Steels. The State Bank of India, holding the entire voting share in the committee of creditors as the sole secured financial creditor, had approved it. That should have been close to the end of the story, but it was not.
The appellants came from two different corners of the dispute. Amba Grains Private Limited and others, an unsuccessful prospective resolution applicant whose own bid had not been selected, filed one set of appeals. The company's suspended directors, Anil Khurana and Krishan Mohan Mendiratta, who also stood as personal guarantors, filed others. Between them, the appeals alleged that the resolution professional and the committee of creditors had let the process run improperly, though the specific grounds varied across the five appeals.
The National Company Law Appellate Tribunal was not persuaded that any of this gave it a reason to interfere. The bench held that neither the Appellate Tribunal nor the Adjudicating Authority can act as a court of appeal sitting over a committee of creditors' commercial decision once that decision has been approved. Its own review, the tribunal said, is confined to checking statutory compliance, specifically whether the plan satisfies Section 30(2) of the Insolvency and Bankruptcy Code and whether the approval process met the requirements of Section 32 read with Section 61(3).
That framing leaned heavily on the Supreme Court's reasoning in the Kalyani Transco line of cases, which has repeatedly held that the commercial wisdom of a committee of creditors is not something a tribunal gets to second-guess outside the specific statutory grounds the Code itself provides. The NCLAT's order here applies that principle to an unsuccessful bidder and to suspended directors alike: neither position, on its own, opens the door to a broader merits review of why the creditors chose the plan they chose.
For an unsuccessful resolution applicant like Amba Grains, the practical message is blunt. Losing a bid, even where the applicant believes its own proposal offered more value, does not by itself create a ground of appeal against the plan the creditors actually picked, unless the applicant can point to a specific failure in the Section 30(2) compliance checklist or a defect in how the approval was processed under Sections 32 and 61(3). General dissatisfaction with the outcome, without a statutory hook, goes nowhere at the appellate stage.
For suspended directors and personal guarantors, the case reinforces a similar limit. Their stake in the company, and their exposure as guarantors, gives them standing to appeal, but it does not expand what the Appellate Tribunal is willing to examine once a plan has cleared the creditors' vote and the NCLT's sanction. The scope of review stays fixed to the statute regardless of who is asking the tribunal to look again.
The decision sits within a broader pattern in Indian insolvency law of appellate tribunals declining to reopen commercial decisions that creditors have already made, a pattern that has hardened considerably since the Supreme Court's repeated emphasis on the finality of creditor-approved plans. For insolvency professionals and resolution applicants, the case is one more data point confirming that the window for contesting a plan's substance effectively closes once the committee of creditors has voted and the adjudicating authority has sanctioned it, leaving only narrow, statute-specific grounds for anyone still unhappy with the result.
There is also a timing lesson buried in how long this dispute took to reach a final answer. The underlying plan was approved by the NCLT Delhi bench in June 2026, yet five separate appeals kept the matter alive through the summer before the Appellate Tribunal cleared them. Every month that an approved plan remains under appeal is a month in which the resolution applicant cannot fully step into the company, employees and operational creditors wait longer for the benefits the plan promised, and the very value the Code is designed to preserve risks eroding further. Tribunals weighing how much latitude to give appeals of this kind have good reason to move quickly once it becomes clear that no statutory ground, as opposed to a general grievance about the outcome, is actually being pressed.