# In the matter of Jai Agarwal vs. Satyendra Prasad Khorani & Ors.

> Read the full IBC case summary for In the matter of Jai Agarwal vs. Satyendra Prasad Khorani & Ors.. NCLAT judgment dated 2025-09-02. Citation:…

- **Court:** NCLAT
- **Order date:** 2 Sept 2025
- **Citation:** TCN-2025-NCLAT-00495
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/nclat-new-delhi/jai-agarwal-vs-satyendra-prasad-khorani-ors-e4a3de12

## Summary

### Background

The appellant, an unsuccessful bidder in an e-auction of a corporate debtor's assets, challenged the auction's validity before the NCLT, alleging irregularities and collusion by the liquidator. The NCLT dismissed his application, leading to this appeal before the NCLAT.

## Facts

Jai Agarwal, the appellant, participated in an e-auction for the sale of assets of M/s Atlas Alloy (India) Private Limited, a corporate debtor under liquidation. The liquidator, Satyendra Prasad Khorania, conducted the e-auction on September 6, 2023. The appellant alleged irregularities, collusion, and unfair conduct by the liquidator, claiming he was the sole genuine participant until the last few minutes of the auction.

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## Issues and analysis

### Issue 1: Whether the e-auction conducted on September 6, 2023, was vitiated by fraud, collusion, or material…

**Ratio:** An e-auction is not vitiated by fraud, collusion, or material irregularity if the rival…

**Reasoning:** The NCLAT examined the appellant's allegations against documentary evidence. It found…

**Interpretation:** The court interpreted the requirements for a valid e-auction under the…

**Application:** The NCLAT applied this interpretation to the facts, concluding that the…

## Parties

- **Judges:** Indevar P…
- **Advocates:** For Appel…; Avin Chhangani,…; +6 more

## Timeline

- **August 11, 2023 — Public Annou…**: Liquidator issued a public announcement for the e-auction of the corporate debtor's…
- **August 14, 2023 — E-auction Documents…**: E-auction process document and terms and conditions were made available on the designated…

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