![Fresh Form-G Kept in Abeyance Till NCLAT Decides Appeal Against Rejection of Revised Resolution Plan: Supreme Court in Hari Global Recreation and Amusement LLP v. Beeram Singh [2026 INSC 1045]](/assets/images/article-corporate.svg)
Quick Answer: Where an appeal against the NCLT's refusal to approve a revised resolution plan is pending, the Supreme Court directed that the fresh Form-G issued to invite new resolution plans be kept in abeyance until the NCLAT decides the appeal, so that the appeal of the Successful Resolution Applicant is not rendered infructuous. The NCLAT was requested to decide the appeal expeditiously.
In Hari Global Recreation and Amusement LLP v. Beeram Singh & Ors. (2026 INSC 1045), the Supreme Court directed that the fresh Form-G, issued to invite new resolution plans after the NCLT refused to approve the appellant's revised resolution plan, be kept in abeyance during the pendency of the appellant's appeal before the NCLAT (paras 1, 3–4). A Bench of Justice J.B. Pardiwala and Justice K. Vinod Chandran requested the NCLAT to dispose of the appeal expeditiously and disposed of the civil appeal without any observation on the merits (paras 3–4).
Status: Civil appeal disposed of with a modification of the NCLAT's interim order; fresh Form-G kept in abeyance till disposal of the appeal by the NCLAT (paras 3–4).
Headnote: Fresh Form-G Kept in Abeyance Pending NCLAT Appeal
Insolvency and Bankruptcy Code, 2016 – Corporate Insolvency Resolution Process – Revised resolution plan – Refusal of approval by NCLT – Appeal before NCLAT – Interim stay – Fresh Form-G inviting new resolution plans – Successful Resolution Applicant – Appeal likely to be rendered infructuous – Expeditious disposal.
Held: (i) The NCLAT had disposed of the stay application by only observing that the fresh process commenced by issuance of fresh Form-G would remain subject to the final disposal of the appeal, without granting the stay prayed for (para 1).
(ii) The grievance of the Successful Resolution Applicant was that, by the time its appeal is decided, new plans would have come for consideration and the appeal itself could be rendered infructuous (para 1).
(iii) Since the appeal is pending before the NCLAT and ought to be disposed of expeditiously, the Form-G is directed to be kept in abeyance during the pendency of the appeal (para 3).
(iv) The parties shall cooperate and avoid unnecessary adjournments, and the NCLAT is requested to decide the appeal as early as possible; no observation is made on the merits (paras 3–4).
(paras 1–4)
Case Details: Hari Global Recreation and Amusement LLP v. Beeram Singh (2026 INSC 1045)
Final Outcome: Civil appeal disposed of; fresh Form-G kept in abeyance till disposal of the appeal by the NCLAT; NCLAT requested to decide the appeal expeditiously; no observation on merits.
Case: Hari Global Recreation and Amusement LLP v. Beeram Singh & Ors.
Neutral Citation: 2026 INSC 1045
Case No.: Civil Appeal No. 12970 of 2026
Court: Supreme Court of India (Civil Appellate Jurisdiction) – Non-Reportable
Date of Decision: 21 September 2026
Bench: Justice J.B. Pardiwala and Justice K. Vinod Chandran (Order; no named author)
Relevant Acts & Sections: Insolvency and Bankruptcy Code, 2016 – Corporate Insolvency Resolution Process; Form-G (invitation for resolution plans)
Impugned Order: Order of the National Company Law Appellate Tribunal, New Delhi disposing of the appellant's stay application without granting a stay, in the appeal against the NCLT, New Delhi's refusal to approve the revised resolution plan (para 1)
Counsel: Dr. Abhishek Manu Singhvi, Senior Advocate, for the appellant; Mr. Navin Pahwa, Senior Advocate, for the respondent/Resolution Professional; Mr. Deepak Khurana for the caveator (para 2)
Source: Supreme Court of India (official website)
Key Holdings of the Supreme Court
- The fresh Form-G inviting new resolution plans is kept in abeyance during the pendency of the appeal before the NCLAT (paras 3–4).
- The modification was made because the Successful Resolution Applicant's appeal could otherwise be rendered infructuous by new plans coming up for consideration (paras 1, 3).
- The NCLAT is requested to dispose of the appeal expeditiously, and the parties are directed to cooperate without seeking unnecessary adjournments (para 3).
- The civil appeal was disposed of without any observation on the merits of the matter (para 4).
Brief Facts of the Case
The appellant was the Successful Resolution Applicant (SRA) in a corporate insolvency resolution process. The National Company Law Tribunal, New Delhi refused approval of the revised resolution plan submitted by the appellant (para 1).
The appellant appealed to the National Company Law Appellate Tribunal, New Delhi. Though the NCLAT dealt with the issue elaborately, it did not grant the stay prayed for; it disposed of the stay application observing that the fresh process, commenced by issuance of a fresh Form-G, would remain subject to the final disposal of the appeal (para 1).
The appellant approached the Supreme Court, contending that by the time the appeal is decided, new plans would have come for consideration and there was every chance of the appeal being rendered infructuous. The Resolution Professional supported the SRA, and a caveator was also heard (paras 1–2).
Issues Before the Supreme Court
- Whether the fresh process under the new Form-G should be allowed to continue while the SRA's appeal against the refusal of approval of its revised resolution plan is pending before the NCLAT (paras 1, 3).
- What interim arrangement would prevent the pending appeal from being rendered infructuous (paras 3–4).
Court's Findings and Reasoning
Grievance of the SRA (para 1): The appellant's concern was that new resolution plans would come up for consideration before its appeal was decided, making the appeal infructuous.
Parties heard (para 2): The Court heard Senior Counsel for the appellant, Senior Counsel for the Resolution Professional, who supported the SRA, and counsel for the caveator.
Form-G kept in abeyance (para 3): As the appeal is pending before the NCLAT and ought to be disposed of expeditiously, the Court directed only that the Form-G be kept in abeyance during the pendency of the appeal, and requested the NCLAT to decide the appeal early.
Cooperation of parties (para 3): The parties were directed to cooperate and complete the proceedings as soon as possible, without seeking unnecessary adjournments.
No view on merits (para 4): The appeal was disposed of with the modification of keeping Form-G in abeyance, without any observation on the merits.
Final Outcome and Directions
- The fresh Form-G is to be kept in abeyance till disposal of the appeal by the NCLAT (paras 3–4).
- The NCLAT is requested to dispose of the appeal expeditiously; parties shall cooperate and not seek unnecessary adjournments (para 3).
- Civil appeal disposed of without any observation on the merits; pending applications rejected (paras 4–5).
Legal Principle Laid Down
Where a Successful Resolution Applicant's appeal against the NCLT's refusal to approve its resolution plan is pending, and a fresh invitation for resolution plans could render that appeal infructuous, the appellate forum may keep the fresh Form-G process in abeyance until the appeal is decided, while ensuring that the appeal is heard and disposed of expeditiously.
Precedents Relied Upon
- No precedent is cited in the order.
Important Paragraphs of the Judgment
Verbatim extracts from the judgment. For the full text, refer to the judgment PDF below.
Para 1: "The grievance of the appellant, the Successful Resolution Applicant (SRA) is that by the time the appeal is decided, new plans would have come for consideration and there is every chance of the appeal itself being rendered infructuous."
Para 3: "Since the appeal is pending before the NCLAT, which ought to be disposed of expeditiously, we would only direct the Form-G to be kept in abeyance during the pendency of the appeal."
Para 3: "The parties shall also cooperate in the hearing without seeking unnecessary adjournments, in which event we are sure that the NCLAT would endeavour to dispose of the appeal itself as early as possible."
Para 4: "With the above modification, insofar as keeping Form-G in abeyance, till disposal of the matter by the NCLAT, we dispose of this civil appeal, without any observation on the merits of the matter."
Practical Impact of the Ruling
- For resolution applicants: A Successful Resolution Applicant whose plan is rejected can seek to have a fresh Form-G process held in abeyance so that its appeal does not become infructuous (paras 1, 3).
- For Resolution Professionals and CoCs: A fresh invitation for resolution plans may be put on hold while a challenge to the rejection of an earlier plan is pending (para 3).
- For the NCLAT and litigants: Such appeals are expected to be decided expeditiously, and parties must avoid unnecessary adjournments (para 3).
FAQs on Fresh Form-G Pending NCLAT Appeal
1. What did the Supreme Court decide in Hari Global Recreation and Amusement LLP v. Beeram Singh?
It directed that the fresh Form-G be kept in abeyance until the NCLAT decides the appellant's appeal against the NCLT's refusal to approve its revised resolution plan, and requested the NCLAT to decide the appeal expeditiously (paras 3–4).
2. Why did the appellant approach the Supreme Court?
The NCLAT had not granted a stay, and the appellant feared that new resolution plans would be considered before its appeal was decided, making the appeal infructuous (para 1).
3. What had the NCLAT ordered on the stay application?
It disposed of the stay application observing that the fresh process started by the new Form-G would remain subject to the final disposal of the appeal (para 1).
4. Did the Supreme Court decide the merits of the resolution plan?
No. The civil appeal was disposed of without any observation on the merits of the matter (para 4).
5. What did the Court direct the parties to do?
To cooperate and complete the proceedings as soon as possible, without seeking unnecessary adjournments before the NCLAT (para 3).
Keywords: 2026 INSC 1045, Hari Global Recreation and Amusement LLP v. Beeram Singh, Form-G in abeyance, revised resolution plan, Successful Resolution Applicant, NCLAT appeal, NCLT refused approval, CIRP, Insolvency and Bankruptcy Code, Justice J.B. Pardiwala, Justice K. Vinod Chandran, Supreme Court non-reportable judgment
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Download Judgment PDF – Hari Global Recreation and Amusement LLP v. Beeram Singh
Source: Supreme Court of India (official website).