NCLAT Expunges Personal Strictures Against Resolution Professional in Rancom Healthcare CIRP
Case Overview
Case Name: Pragiti Construction Vs Committee of Creditor Represented by Mahavir Medicare & Anr (NCLAT Delhi)
Appeal Number: I.A. No. 2481 & 2480 of 2026
Date of Order: 06/07/2026
Forum: National Company Law Appellate Tribunal, Principal Bench, New Delhi
Background and Context
The National Company Law Appellate Tribunal (NCLAT), Delhi, recently adjudicated upon two Interlocutory Applications filed by the erstwhile Resolution Professional of Rancom Healthcare Pvt. Ltd., seeking deletion of certain adverse personal observations and consequential directions recorded against him in paragraph 99 of the Tribunal's earlier judgment dated 06.02.2026.
The genesis of the dispute lay in a set of company appeals filed by Pragiti Construction challenging orders passed by the Adjudicating Authority, which had approved the Resolution Plan of Mahavir Medicare — the sole Operational Creditor and the only member of the Committee of Creditors (CoC) — while declining to consider the competing Resolution Plan submitted by Pragiti Construction. Through its judgment dated 06.02.2026, the NCLAT had:
- Set aside the approved Resolution Plan of Mahavir Medicare
- Directed initiation of liquidation proceedings against Rancom Healthcare Pvt. Ltd.
- Recorded adverse personal observations and issued consequential directions against the Resolution Professional in paragraph 99
Aggrieved specifically by the personal remarks — and not by the substantive legal findings — the erstwhile Resolution Professional approached the Hon'ble Supreme Court in Civil Appeal Nos. 3060-3061 of 2026. The Supreme Court, by order dated 13.03.2026, declined to interfere with the judgment but expressly granted liberty to the applicant to return to the NCLAT seeking expungement of the remarks. The present applications were filed before the NCLAT pursuant to that liberty, under Rule 11 of the NCLAT Rules, 2016.
The Supreme Court's Order (Extracted)
"We do not want to interfere in the matter. It shall be open for the appellants to go back to the NCLAT with prayer to expunge the remarks. In view of the aforesaid, the appeals are disposed of."
— Supreme Court of India, Civil Appeal Nos. 3060-3061/2026
Factual Matrix of the CIRP
Initiation and Constitution of the CoC
The Corporate Insolvency Resolution Process of Rancom Healthcare Pvt. Ltd. was initiated pursuant to an order dated 21.12.2023 of the Adjudicating Authority, on an application filed by Mahavir Medicare under Section 9 of the Insolvency and Bankruptcy Code, 2016 (IBC). The erstwhile Resolution Professional was appointed as the Interim Resolution Professional upon commencement of the CIRP.
Following the public announcement, no creditor other than Mahavir Medicare filed any claim. Since no Financial Creditor existed, the CoC was constituted exclusively with Mahavir Medicare as its sole member, holding an admitted operational debt of Rs. 14,62,35,160/-, under Section 21 of the IBC read with Regulation 16 of the CIRP Regulations.
Submission and Approval of Resolution Plans
During the CIRP, both Mahavir Medicare and Pragiti Construction were found eligible to submit Resolution Plans. Mahavir Medicare's plan was approved by the sole-member CoC at its 5th meeting held on 07.06.2024. Subsequently, Pragiti Construction submitted its Resolution Plan on 13.06.2024, which was not placed before the CoC, and the same was communicated to Pragiti Construction on 16.06.2024.
Adjudicating Authority's Directions and the 6th CoC Meeting
Pragiti Construction filed IA No. 358 of 2024 before the Adjudicating Authority, challenging the non-consideration of its Resolution Plan. The Resolution Professional simultaneously filed IA No. 401 of 2024 seeking approval of Mahavir Medicare's plan.
By order dated 10.09.2024, the Adjudicating Authority directed the CoC to freshly consider Pragiti Construction's Resolution Plan. Notably, by this stage, the CIRP period had already expired on 18.06.2024. Mahavir Medicare's already approved plan was not remitted back for reconsideration and remained pending before the Adjudicating Authority.