Worlds Window Exim Private Limited went into corporate insolvency resolution on 16 May 2025, on a Section 7 petition filed by Central Bank of India. Almost a year later, on 23 April 2026, the committee of creditors voted to approve a resolution plan put up by Dickey Special Situation Investment Trust-DSSF Series 2. On paper, the applicant had cleared the hurdle that matters most in CIRP, a majority vote of the committee. What it had not cleared, the National Company Law Tribunal found, was the regulatory bar that sits underneath that vote.
The NCLT rejected the plan on 14 August 2026 and sent the company into liquidation, even though the committee had already said yes to it. The tribunal's objection went to the plan's value and its content together. At roughly Rs 7 crore, the offer sat well below the company's own liquidation value of about Rs 9.42 crore. A plan priced under liquidation value is not automatically bad in law, and the NCLT did not rest its order on that figure alone. What it found fatal was that the plan said nothing about why Worlds Window Exim had defaulted in the first place, a disclosure that Regulation 38(3)(a) of the CIRP Regulations treats as mandatory, not optional. The resolution applicant and Prudent ARC Limited, the financial creditor holding 94.86 per cent of the voting share in the committee, both appealed.
Before the NCLAT, the appellants leaned on the committee's commercial wisdom, the doctrine that ordinarily keeps appellate forums from second-guessing a plan the creditors themselves have accepted. The bench of Justice Mohammad Faiz Alam Khan and Technical Member Arun Baroka did not treat that doctrine as a shield here. Commercial wisdom operates within the four corners of the statute, and a plan that skips a mandatory disclosure is not saved merely because the creditors voted for it anyway. The appellate tribunal read Regulation 38(3)(a) as doing real work, not as a formality a resolution applicant can gloss over once the numbers otherwise look acceptable to the lenders in the room.
The order also touched the position of a dissenting financial creditor, protected under Section 30(2)(b) of the Code regardless of how the majority votes. The NCLT had found that the Rs 7 crore structure sat uneasily with that protection, and the NCLAT's reading of the resolution plan did not disturb that finding. Put together, a plan has to clear two separate tests, the commercial one that the committee applies and the statutory one that Parliament has fixed independent of any vote. Worlds Window Exim's plan cleared only the first.
There was a narrower point on which the resolution applicant and Prudent ARC did get relief. The NCLT's order had capped Prudent ARC's entitlement to the amount it had itself paid to Central Bank of India to acquire the debt, rather than the face value of that debt. The NCLAT held that question premature at the liquidation stage and set the cap aside, keeping every contention on that score open for decision later, likely before the liquidator or at the stage of distribution. Both appeals were otherwise dismissed, and liquidation stands.
A separate thread in the NCLT's order, an investigation into the affairs of the company, was left undisturbed as well. Nothing in the appellate record suggests the NCLAT revisited that direction, which keeps the scrutiny of the company's conduct during the CIRP alive even as the asset side moves to liquidation.
For resolution applicants, the lesson is procedural rather than commercial. A plan can be lean on price if the committee is willing to accept it, but it cannot be silent on the cause of default and still expect the NCLT to wave it through on the strength of a CoC vote. For financial creditors who have bought distressed debt at a discount, the order is a reminder that what they recover in liquidation may still turn on what they paid, a question the NCLAT has now left open rather than settled either way.
Liquidation proceedings for Worlds Window Exim continue under the appointed insolvency professional, with the entitlement dispute between Prudent ARC and the estate still to be worked out.