NCLAT Approves Adani Rs 14500 Crore Resolution Plan for Jaiprakash Associates Under IBC

The National Company Law Appellate Tribunal (NCLAT) in May 2026 dismissed the appeals filed by Vedanta and cleared the path for Adani Enterprises' approximately Rs 14,500 crore resolution plan for Jaiprakash Associates Limited. The Committee of Creditors had approved the Adani resolution plan in November 2025 with over 93 percent voting support after a competitive bidding process. This order represents one of the largest corporate insolvency resolutions under the Insolvency and Bankruptcy Code 2016, involving a company with significant exposure in cement, real estate, power, and infrastructure sectors.

Background: Jaiprakash Associates Insolvency

Jaiprakash Associates Limited was one of India's largest infrastructure conglomerates with operations spanning cement manufacturing, construction, power generation, and real estate development. The company faced severe financial distress due to overleveraging, execution delays in real estate projects, and an overall slowdown in the infrastructure sector. The corporate insolvency resolution process (CIRP) was initiated against the company under the IBC after creditors moved the National Company Law Tribunal. The CIRP attracted multiple resolution applicants, reflecting the valuable underlying assets held by the corporate debtor, including cement plants, power generation assets, and extensive land banks across northern India.

The Resolution Plan and CoC Approval

The Adani resolution plan offered approximately Rs 14,500 crore to the creditors of Jaiprakash Associates. The plan was approved by the Committee of Creditors with more than 93 percent voting share in favour, well above the 66 percent threshold required under Section 30(4) of the IBC. The plan addressed the claims of financial creditors, operational creditors, and employees, and included proposals for the continuation of the corporate debtor as a going concern. The NCLT approved the plan after examining its compliance with the mandatory requirements of Section 30(2) of the IBC, including the payment of insolvency resolution process costs, minimum payments to operational creditors and dissenting financial creditors, and consistency with applicable laws.

NCLAT Dismisses Vedanta Appeals

Vedanta, which had also submitted a competing resolution plan during the CIRP, challenged the approval of the Adani plan before the NCLAT. The appellate tribunal examined the challenge on its merits and dismissed the appeals, finding no infirmity in the CoC's commercial decision to prefer the Adani plan. The NCLAT reiterated the settled principle that the CoC's commercial wisdom in selecting a resolution plan is given primacy, and judicial interference is limited to examining whether the plan meets the statutory requirements of the IBC. The tribunal found that the process conducted by the resolution professional was fair, transparent, and in compliance with the regulations framed by the Insolvency and Bankruptcy Board of India.

Implications for IBC Jurisprudence

This resolution reinforces several important principles of IBC law. The primacy of CoC commercial wisdom means that once a resolution plan receives the requisite majority approval, courts will not substitute their judgment for that of the creditors unless there is a clear violation of law. The high recovery rate achieved through competitive bidding demonstrates the effectiveness of the IBC framework for maximising value realisation from distressed assets. The dismissal of a competing bidder's appeal also clarifies that unsuccessful resolution applicants have limited grounds to challenge the selection process, primarily restricted to allegations of procedural irregularity rather than mere dissatisfaction with the commercial outcome.

Practical Takeaways

For stakeholders in IBC proceedings, this case offers several lessons. Creditors benefit from competitive bidding processes that attract multiple resolution applicants, as this drives up the recovery amount. Resolution applicants must prepare for the possibility that unsuccessful competitors may challenge the outcome, building in appropriate timelines for appellate proceedings. The 93 percent CoC approval demonstrates that building consensus among diverse creditor groups, while difficult, significantly strengthens the legal position of the resolution plan against subsequent challenges. For homebuyers who had booked properties in Jaiprakash projects, the resolution plan's treatment of their claims as financial creditors will determine the extent of their recovery, whether through possession of completed units or monetary settlement.