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Ghanashyam Mishra And Sons Private ... vs Edelweiss Asset Reconstruction ... on 13 April, 2021

Upon consideration of the factual matrix in Ghanshyam case, it is seen that there is a fundamental distinction Signature Not Verified O.M.P. (COMM) 469/2025 & connected matters Page 45 of 85 Digitally Signed By:NEERU Signing Date:05.05.2026 18:13:51 of facts and therefore, the ratio of those documents cannot be applied to the present case. In the case of Ghanshyam, the Clean Slate Theory (CST) was applied in favour of third-party Resolution Applicants who had no prior connection with the corporate debtor and who took over the company pursuant to a resolution plan approved under Section 31 of the IB Code. The ratio of the above judgment in Ghanshyam of the Hon'ble Supreme Court was clearly intended to shield bona fide, unrelated Resolution Applicants from the risk of undecided or undisclosed claims that could threaten the viability of the revival plan. The said decision in Ghanshyam Mishra is distinguishable on facts, since in the present case no third party Resolution-Applicant is involved.
Supreme Court of India Cites 110 - Cited by 360 - B R Gavai - Full Document
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