# In the matter of Bizloan Private Limited vs. Amit Chandrashekhar Poddar & Ors.

> Read the full IBC case summary for In the matter of Bizloan Private Limited vs. Amit Chandrashekhar Poddar & Ors.. NCLAT judgment dated 2025-07-03. Citation:…

- **Court:** NCLAT
- **Order date:** 3 Jul 2025
- **Citation:** TCN-2025-NCLAT-00337
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/nclat-new-delhi/bizloan-private-limited-vs-amit-chandrashekhar-poddar-ors-eb25135f

## Summary

### Background

The appellant, Bizloan Private Limited, a financial creditor, provided credit facilities to Autocop (India) Private Limited (corporate debtor) through sales bill discounting. During the Corporate Insolvency Resolution Process (CIRP) and subsequent liquidation, the appellant was classified as an unsecured creditor instead of a secured financial creditor by the Adjudicating Authority, despite having registered its charge with CERSAI. The appellant filed an application seeking reclassification as a secured financial creditor, which was rejected, leading to this appeal.

## Facts

Bizloan Private Limited, the appellant, acted as a financial creditor to Autocop (India) Private Limited, the corporate debtor, by providing credit facilities totaling Rs. 1 Crore through sales bill discounting and purchase bill discounting. The Corporate Insolvency Resolution Process (CIRP) was initiated against the corporate debtor by the Adjudicating Authority on March 16, 2022. Subsequently, the Interim Resolution Professional (IRP) published Form-A on March 24, 2022, and the appellant filed its claims in Form C on April 4, 2022, which were admitted in full by the Resolution Professional without specifying whether they were secured or unsecured.

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## Issues and analysis

### Issue 1: Whether a financial creditor automatically becomes a "Secured Financial Creditor" solely by having…

**Ratio:** Security interest can be proved by registration of charge with CERSAI, and it is not…

**Reasoning:** The NCLAT noted that Regulation 21 of the IBBI (Liquidation Process) Regulations, 2016,…

**Interpretation:** The court interpreted Regulation 21 of the IBBI (Liquidation Process)…

**Application:** Given that the appellant had registered its charge with CERSAI, the NCLAT…

## Parties

- **Judges:** Rakesh Kuma…; Mohammad Faiz…; +1 more
- **Advocates:** For Appel…; Mohit Cho…; +7 more

## Timeline

- **March 16, 2022 — CIRP Init…**: Corporate Insolvency Resolution Process (CIRP) initiated against the Corporate Debtor by…
- **March 24, 2022 — Form-A Publ…**: Interim Resolution…

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