Ashdan Properties Pvt. Ltd. vs DSK Global Education a 2025 INSC 959 - NCLAT Rules - IBC - Certified Copy Of Impugned Order

"An appeal before NCLAT must be accompanied by a certified copy of the order impugned."

Note

Sign in to read our notes on this judgment. Register @ citecase.in to subscribe !

Read Judgment

National Company Law Appellate Tribunal Rules, 2016 - Rule 14,22 - IBC- Even if an appeal is entertained within the initial 30 day-period without a certified copy of the order, by granting exemption under Rule 14, it can only be for a limited period to enable due compliance with the mandate of Rule 22(2) by filing a certified copy at least at a later date and within the time stipulated by the NCLAT. Such exemption cannot be to the extent of completely dispensing with the filing of a certified copy, which would annihilate the clear mandate of Rule 22(2) of the NCLAT Rules which categorically uses the word ‘shall’ to emphasize that an appeal must be accompanied by a certified copy of the order impugned. (Para 11)

Case Info


Case Name and Neutral Citation

  • Case Name: Ashdan Properties Pvt. Ltd. & Ors. v. DSK Global Education and Research Pvt. Ltd. & Anr.
  • Neutral Citation: 2025 INSC 959

Coram

  • Justice Sanjay Kumar
  • Justice Satish Chandra Sharma

Judgment Date

  • August 12, 2025

Caselaws and Citations Referred

  1. V. Nagarajan v. SKS Ispat & Power Ltd. and others
    • Citation: (2022) 2 SCC 244
  2. Essar Steel (India) Ltd. (CoC) v. Satish Kumar Gupta
    • Citation: (2020) 8 SCC 531; (2021) 2 SCC (Civ) 443
  3. Innoventive Industries Ltd. v. ICICI Bank
    • Citation: (2018) 1 SCC 407; (2018) 1 SCC (Civ) 356
  4. Gujarat Urja Vikas Nigam Ltd. v. Amit Gupta
    • Citation: (2021) 7 SCC 209; (2021) 4 SCC (Civ) 1
  5. A Rajendra vs. Gonugunta Madhusudhan Rao and others
    • Citation: 2025 INSC 4479
  6. Innovators Cleantech Pvt. Ltd. vs. Passari Multi Projects Pvt. Ltd.
    • Citation: (2024) ibclaw.in 452 NCLAT

Statutes/Laws Referred

  • Insolvency and Bankruptcy Code, 2016 (IBC)
    • Section 62 (Appeal to Supreme Court)
    • Section 61(2) (Appeal to NCLAT and limitation)
    • Section 12(3) (Timeline for completion of insolvency resolution)
  • Limitation Act, 1963
    • Section 12 (Exclusion of time for obtaining copy of order)
  • National Company Law Appellate Tribunal Rules, 2016
    • Rule 22(2) (Certified copy requirement)
    • Rule 14 (Exemption from compliance)
    • Rule 15 (Extension of time)
  • Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) Regulations, 2016
    • Regulation 40-A (Model timeline for insolvency process)