# Prabhat Ranjan vs. Milind Kasodekar, Liquidator (for Phadnis Properties Ltd.) & Ors.

> NCLAT judgment dated 6 Jan 2026. Citation: TCN-2026-NCLAT-00011. This appeal was filed against an order dated 11.07.2025 by the National Company Law Tribunal…

- **Court:** NCLAT
- **Order date:** 6 Jan 2026
- **Citation:** TCN-2026-NCLAT-00011
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/nclat-new-delhi/prabhat-ranjan-vs-milind-kasodekar-liquidator-1n1rn

## Summary

### Background

This appeal was filed against an order dated 11.07.2025 by the National Company Law Tribunal (NCLT), Mumbai Bench, in I.A. No. 5365/2024. The appellant, Prabhat Ranjan, had sought various prayers including a declaration that certain land at Keshavnagar, Pune, does not form part of the liquidation estate of the corporate debtor (Phadnis Properties Ltd.), peaceful possession of the land, relinquishment of claim by Respondent No. 3, and a direction for Respondent No. 1 to apply for the release of the property. The appellant also has another application, I.A. 1430/2025, pending before the NCLT concerning an increase in FSI (Floor Space Index), and other landowners have similar pending applications.

## Facts

An appeal was filed against an order dated 11.07.2025 passed by the National Company Law Tribunal, Mumbai Bench, Court – II in I.A. No. 5365/2024.

The appellant had sought a declaration that land at Plot No. R-05, Admeasuring About 571.33 sq. mtrs., situated at Keshavnagar, Mundhava, Pune, does not form part of the liquidation estate of the corporate debtor, Phadnis Properties Ltd.

The appellant also prayed for a direction to the respondent to handover peaceful possession of the land, a direction to Respondent No. 3 to relinquish its claim, and a direction to Respondent No. 1 to move an application for release of the property.

The appellant subsequently filed another application, I.A. 1430/2025, which is pending consideration, concerning an increase in FSI.

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## Issues and analysis

### Issue 1: Whether the Adjudicating Authority's observation regarding FSI disputes being civil in nature …

**Ratio:** An observation made by an adjudicating authority in a prior order concerning its

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**Reasoning:** The NCLAT noted that I.A. 1430/2025, concerning FSI increase, is a separate application

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**Interpretation:** The NCLAT interpreted that the NCLT's prior statement about its lack of

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**Application:** By dismissing the appeal but issuing a clarification, the NCLAT ensured that

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## Parties

- **Judges:** Ashok Bh…; Barun M…
- **Appellants:** Prabhat R…
- **Respondents:** Phadnis Properties…; Milind Kas…
- **Other parties:** Insolvency and…; Liquidation…; +6 more

## Timeline

- **2021-05-10 — Prior Order for…**: An order was passed by 'this Hon'ble Tribunal' for the release of property in favour of…
- **2025-07-11 — Adjudicating Authority's…**: Adjudicating authority (National Company Law Tribunal, Mumbai Bench, Court – II) passed…

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