# In the matter of Praful Satra vs. Vaishali Patrikar (RP) and Ors.

> NCLAT judgment dated 2025-09-04. Citation: TCN-2025-NCLAT-00487. The appeal was filed by Praful Satra, the suspended director of Satra Properties (India)…

- **Court:** NCLAT
- **Order date:** 4 Sept 2025
- **Citation:** TCN-2025-NCLAT-00487
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/nclat-new-delhi/praful-satra-vs-vaishali-patrikar-954dac9a

## Summary

### Background

The appeal was filed by Praful Satra, the suspended director of Satra Properties (India) Limited, challenging the order dated 26.07.2024 passed by the National Company Law Tribunal, Mumbai Bench-I, approving the resolution plan submitted by MJ Shah Consortium.

## Facts

Praful Satra, the suspended director of Satra Properties (India) Limited, filed appeals challenging the approval of the resolution plan.

The Appellant contended that the Adjudicating Authority erred in not considering collusion between Respondent No. 1 and 3 to transfer assets of the Corporate Debtor at low value.

The Appellant contended that the significant 50% difference in valuations between assessment made by Sadashiv appointed by him and that of the Registered Valuers Adroit, RNC and Gunjan directly reduces payouts to secured creditors, undermining the CIRP.

…

## Issues and analysis

### Issue 1: Whether the Appellant has locus standi to …

**Ratio:** The Appellate Tribunal held that a promoter of a corporate debtor has no locus to

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**Reasoning:** The Tribunal relied on the decisions in Ramesh Kesavan (supra) and Ravi Shankar Vedam

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**Interpretation:** A suspended director of the Corporate Debtor has locus to challenge the CIRP of

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**Application:** The Appellant, being a suspended director, does not have the locus standi to

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## Parties

- **Judges:** Naresh Sa…; Rakesh Kuma…; +1 more
- **Appellants:** Praful…
- **Respondents:** Satra Properties…; Vaishali Pa…; +3 more
- **Other parties:** Vistra ITCL…; India Infoline…; +3 more
- **Advocates:** Malak B…; Neeha N…; +17 more

## Timeline

- **2020-08-03 — CIRP Init…**: Adjudicating Authority admitted the petition, initiated CIRP, and appointed Mr. Devarajan…
- **2020-10-03 — RP Confir…**: Mr. Devarajan Raman was confirmed 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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