# Sanjeev Kumar Arora vs. Deepak Thukral & Ors.

> NCLAT judgment dated 2026-05-11. Citation: TCN-2026-NCLAT-00199. The appeal challenges an NCLT order dated 21.10.2022, which directed the erstwhile statutory…

- **Court:** NCLAT
- **Order date:** 11 May 2026
- **Citation:** TCN-2026-NCLAT-00199
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/nclat-new-delhi/sanjeev-kumar-arora-vs-deepak-thukral-ors-qlptb

## Summary

### Background

The appeal challenges an NCLT order dated 21.10.2022, which directed the erstwhile statutory auditor (Appellant) to provide information and complete an audit under Section 19 of the IBC, 2016. The Resolution Professional (RP) had sought this information, alleging non-cooperation. The Appellant contended that the audit could not be completed due to non-availability of records from the Corporate Debtor's management and later the RP, that he had already resigned, and that the Committee of Creditors' (CoC) decision to replace him was flawed.

## Facts

On 27.02.2018, Sh. Sanjeev Kumar Arora (Appellant) was appointed as the statutory auditor of M/s Lakshmi Precision Screws Limited (Corporate Debtor) by its Board for the year 2017-2018.

On 15.05.2018, the EOGM of the Corporate Debtor approved the appellant's appointment.

On 24.07.2018, Corporate Insolvency Resolution Process (CIRP) was initiated against the Corporate Debtor.

On 10.09.2018, the appellant sent an e-mail to the Resolution Professional (RP) seeking certain particulars, followed by another e-mail on 27.09.2018.

On 27.09.2018, the RP replied via e-mail, indicating a lack of support from the staff of the Corporate Debtor.

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## Issues and analysis

### Issue 1: Whether a statutory auditor can be considered a "person associated with the management of the …

**Ratio:** A statutory auditor is a professional who holds a mirror to the company's performance and

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**Reasoning:** Section 19(1) mandates cooperation from "the personnel of the corporate debtor, its

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**Interpretation:** Section 19(1) of the IBC is interpreted narrowly to apply only to individuals

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**Application:** The appellant, as a statutory auditor appointed only a couple of months before

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## Parties

- **Judges:** N. Sesha…; Arun Ba…
- **Appellants:** Sh. Sanjeev Kumar…
- **Respondents:** M/s Lakshmi…; Deepak Th…; +1 more
- **Other parties:** Committee of…
- **Advocates:** Arun Sa…; Rahul Kr.…; +3 more

## Timeline

- **2018-02-27 — Appointment of…**: Appellant Sh. Sanjeev Kumar Arora appointed as statutory auditor of the Corporate Debtor…
- **2018-05-15 — EOGM App…**: The EOGM of the Corporate Debtor approved the appointment of the appellant as the…

## Legal provisions

- [Insolvency and Bankruptcy Code, 2016, Section 19 — Personnel to extend co-operation to interim…](https://caseease.in/legal-provisions/insolvency-and-bankruptcy-code-2016/section-19)

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