NCLT Approves Adani's Rs 15000 Crore Resolution Plan for Jaiprakash Associates

The National Company Law Tribunal, Allahabad Bench, has approved Adani Enterprises Limited's resolution plan for Jaiprakash Associates Limited under Section 31 of the Insolvency and Bankruptcy Code, 2016. The oral order, pronounced on March 17, 2026, clears the way for one of the largest insolvency resolutions in India's history, valued at approximately Rs 15,000 crore. The plan received approximately 93 per cent approval from the Committee of Creditors, significantly exceeding the statutory threshold of 66 per cent required under Section 30(4) of the IBC.

Jaiprakash Associates: The Insolvency Background

Jaiprakash Associates Limited, commonly known as JAL, is one of India's largest infrastructure conglomerates with operations spanning cement, real estate, power, and expressways. The company was admitted into the Corporate Insolvency Resolution Process under the IBC after financial creditors initiated proceedings on account of significant debt defaults. The CIRP attracted considerable attention because of the scale of the company's operations, the number of affected stakeholders including thousands of homebuyers in its real estate projects, and the complexity of resolving a diversified group with assets across multiple sectors.

Key Terms of the Adani Resolution Plan

The approved resolution plan provides for a total consideration of approximately Rs 15,000 crore. Of this amount, an upfront payout of approximately Rs 6,000 crore is to be made to the financial creditors, with the remaining amount to be settled over a period of two years. Additionally, Adani Enterprises has committed to infusing up to Rs 800 crore within 180 days of the plan approval to support working capital requirements, capital expenditure, and operational improvements for the ongoing businesses of JAL.

A significant feature of the plan is the immediate delisting of JAL from the stock exchanges with zero consideration for existing shareholders. This is permitted under the IBC framework, where the resolution plan, once approved by the NCLT, binds all stakeholders including shareholders, and the resolution applicant is not required to make an open offer or pay exit consideration to existing shareholders. The implementation is to be carried out through various Adani group entities within 90 days of the March 17, 2026 order.

Vedanta's Challenge and the Supreme Court's Response

Vedanta Limited, which had also submitted a resolution plan for JAL, challenged the NCLT's approval before the National Company Law Appellate Tribunal. Vedanta contended that its plan offered better value to the creditors and raised procedural objections to the evaluation process. The matter also reached the Supreme Court, which declined to interfere with the Adani resolution plan and instead directed the NCLAT to expedite the hearing of Vedanta's appeals. The Supreme Court's approach signals that once a resolution plan has been approved by the CoC with the requisite majority and sanctioned by the NCLT under Section 31, courts are reluctant to stay or reverse the approval absent a clear legal infirmity.

Significance for India's Insolvency Framework

The JAL resolution is one of the highest-value insolvency resolutions in India and demonstrates that the IBC framework is capable of handling complex, multi-sector corporate insolvencies. The 93 per cent CoC approval reflects strong creditor consensus, which is a key metric for the success of any resolution plan under the IBC. The zero-shareholder-consideration delisting, while controversial, is consistent with the IBC's priority framework where shareholders rank below all classes of creditors. The case also illustrates the role of large industrial groups as resolution applicants capable of providing the capital and operational expertise necessary to revive distressed companies at this scale.

Practical Takeaways

Financial creditors and resolution professionals dealing with large insolvencies should study the JAL resolution structure as a template for handling diversified groups. The upfront-plus-deferred payment structure, the working capital infusion commitment, and the multi-entity implementation mechanism are features that may be replicated in future large-scale resolutions. Shareholders of companies in CIRP should be aware that IBC resolutions can result in zero consideration for equity holders, and the Supreme Court's refusal to stay the JAL plan reinforces that shareholder interests are subordinate to creditor recovery under the IBC. Competing resolution applicants should note the high threshold required to overturn a CoC-approved plan, as both the NCLT and the Supreme Court have shown deference to the commercial wisdom of the CoC where the statutory majority has been met.