# Deepti Pankaj Chugh vs. The State Bank of India

> NCLAT judgment dated 2026-07-03. Citation: TCN-2026-NCLAT-00239. Deepti Pankaj Chugh, a personal guarantor for M/s. Aditya Prints Pvt. Ltd., filed a petition…

- **Court:** NCLAT
- **Order date:** 3 Jul 2026
- **Citation:** TCN-2026-NCLAT-00239
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/nclat-new-delhi/deepti-pankaj-chugh-vs-the-state-bank-of-india-8c522

## Summary

### Background

Deepti Pankaj Chugh, a personal guarantor for M/s. Aditya Prints Pvt. Ltd., filed a petition under Section 94 of the IBC seeking initiation of personal insolvency resolution process (PIRP). This petition (CP (IB) No. 76/2025) was dismissed by the NCLT, Ahmedabad Bench, on 24.02.2025 with a cost of ₹1 lakh, without addressing the merits. This was not her first attempt; previous petitions (CP (IB) No. 55/2024 and CP (IB) No. 147/2024) were also dismissed, the latter on grounds of limitation. The Corporate Debtor, M/s. Aditya Prints Pvt. Ltd., is already under liquidation. The State Bank of India (SBI) had issued a demand notice under Section 13(2) of the SARFAESI Act to the personal guarantor on 20.03.2017.

## Facts

Deepti Pankaj Chugh is a personal guarantor for loans availed by M/s. Aditya Prints Pvt. Ltd. from the State Bank of India.

M/s. Aditya Prints Pvt. Ltd. (Corporate Debtor) was put under Corporate Insolvency Resolution Process (CIRP) in 2021 and is currently under liquidation (Liquidation Order dated 20.07.2023).

The Corporate Debtor's credit facilities were classified as Non-performing Asset (NPA) on 28.07.2016, effective from 28.10.2013.

The State Bank of India (SBI) issued a Demand Notice dated 20.03.2017 under Section 13(2) of the SARFAESI Act, 2002, to both the Corporate Debtor and the Appellant (personal guarantor), demanding payment of ₹49,76,13,119.38 within 60 days.

SBI issued a Possession Notice dated 27.01.2022 under Section 13(4) of the SARFAESI Act, 2002.

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## Issues and analysis

### Issue 1: Whether the limitation period for filing an application under Section 94 of the IBC by a personal …

**Ratio:** The limitation period for initiating proceedings against a personal guarantor commences

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**Reasoning:** The NCLAT noted that a separate and independent demand notice under Section 13(2) of the

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**Interpretation:** Mere issuance of a notice under Section 13(2) of the SARFAESI Act to the

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**Application:** The Appellant's Section 94 IBC Petition (CP (IB) No. 76/2025), being a

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## Parties

- **Judges:** Mohd. Faiz Alam…; Arun Ba…
- **Appellants:** Deepti Pankaj…
- **Respondents:** M/s. Aditya…; The State Bank of…
- **Advocates:** Dhiren R…; Siddharth…; +3 more

## Timeline

- **2013-10-28 — NPA Effecti…**: Credit facilities of M/s Aditya Prints Pvt. Ltd. classified as Non-performing Asset (NPA)…
- **2016-07-28 — NPA Classifica…**: The credit facilities advanced to M/s Aditya Prints Pvt. Ltd. by SBI were classified as…

## Legal provisions

- [Insolvency and Bankruptcy Code, 2016, Section 61 — Appeals and Appellate Authority](https://caseease.in/legal-provisions/insolvency-and-bankruptcy-code-2016/section-61)

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