# HDFC Bank Ltd. & Sasmita Rani Samanta vs. Sustainable Outreach and Universal Leadership (Soul) Ltd. & Kalinga Institute of Industrial Technology

> NCLAT judgment dated 2026-09-10. Citation: TCN-2026-NCLAT-00298. Two connected Company Appeals (AT) (Ins.) No. 1716 of 2026 by Financial Creditor HDFC Bank…

- **Court:** NCLAT
- **Order date:** 10 Sept 2026
- **Citation:** TCN-2026-NCLAT-00298
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/nclat-new-delhi/hdfc-bank-ltd-vs-sustainable-outreach-and-universal-lea-7shms

## Summary

### Background

Two connected Company Appeals (AT) (Ins.) No. 1716 of 2026 by Financial Creditor HDFC Bank Ltd. and No. 1717 of 2026 by Ms. Sasmita Rani Samanta (Suspended Director of the Corporate Debtor) were filed against an Adjudicating Authority order dated 21.08.2026. This order allowed Kalinga Institute of Industrial Technology (KIIT), claiming to be an Operational Creditor, to intervene in the Corporate Insolvency Resolution Process (CIRP). Both appellants had settled their disputes with their respective creditors (HDFC Bank and Tata Consultancy) and had filed applications under Section 12A of the IBC for withdrawal of the CIRP, but these proceedings were delayed due to KIIT's intervention.

## Facts

Company Appeal (AT) (Ins.) No. 1716 of 2026 was preferred by the Financial Creditor, HDFC Bank Ltd.

Company Appeal (AT) (Ins.) No. 1717 of 2026 was preferred by Ms. Sasmita Rani Samanta, Suspended Director of the Corporate Debtor.

Both appeals are connected and are being disposed of by a common judgment due to similarity of issues.

The appeals challenge an order dated 21.08.2026 passed by the Adjudicating Authority in Intervention Petition No.6/CB/2026.

The impugned order allowed Kalinga Institute of Industrial Technology (KIIT), claiming to be an Operational Creditor, to intervene in the matter.

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## Issues and analysis

### Issue 1: Whether the Adjudicating Authority erred in allowing the intervention application of Kalinga …

**Ratio:** While intervention by an Operational Creditor may be permissible, it should not unduly

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**Reasoning:** The appellants argued that KIIT had no interest in the Section 12A proceedings and its

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**Interpretation:** The NCLAT implicitly interpreted the intervention, while potentially valid, as

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**Application:** The NCLAT did not explicitly set aside the intervention order but addressed the

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## Parties

- **Judges:** Mohammad Faiz…; Naresh Sa…
- **Appellants:** HDFC Bank…; Sasmita Rani…
- **Respondents:** Sustainable…; Sustainable…; +1 more
- **Other parties:** Kalinga Institute…; Vikky…
- **Advocates:** Sumesh D…; Asav R…; +14 more

## Timeline

- **2026-01-28 — Operational Creditor's…**: Kalinga Institute of Industrial Technology (KIIT) filed its claim of Rs.45 Crore as an…
- **2026-01-31 — Financial Creditor's…**: HDFC Bank Ltd. filed its claim of…

## Legal provisions

- [Insolvency and Bankruptcy Code, 2016, Section 12A — (1) Subject to sub](https://caseease.in/legal-provisions/insolvency-and-bankruptcy-code-2016/section-12a)

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