# State Bank of India & Ors. vs. Jyoti Structures Limited & Ors. > NCLAT judgment dated 2026-05-26. Citation: TCN-2026-NCLAT-00207. The present appeal was filed by several lender banks (Appellants) against an order dated… - **Court:** NCLAT - **Order date:** 26 May 2026 - **Citation:** TCN-2026-NCLAT-00207 - **Category:** IBC - **Source page:** https://caseease.in/cases/ibc/nclat-new-delhi/state-bank-of-india-ors-vs-jyoti-structures-limited-ors-xyuli ## Summary ### Background The present appeal was filed by several lender banks (Appellants) against an order dated 16.02.2026 passed by the National Company Law Tribunal (NCLT), Mumbai Bench-I. The NCLT order arose from contempt applications filed by Jyoti Structures Ltd. (Corporate Debtor) and its shareholders (Respondents). The NCLT had directed the Appellant banks to release rolled-over Bank Guarantee (BG) limits as per an approved resolution plan and Non-Fund Based Facility (NFB) Agreement, failing which they would face one day simple imprisonment. The Corporate Debtor was admitted into CIRP on 04.07.2017, and its resolution plan, which included the roll-over of BGs/LCs by the Appellant banks, was approved on 27.03.2019. The 'Closing Date' for the NFB Agreement was 09.11.2021, by which … ## Facts The Corporate Debtor, Jyoti Structures Ltd. (JSL), was admitted into Corporate Insolvency Resolution Process (CIRP) on 04.07.2017. A resolution plan submitted by Sharad Sanghi (Respondent No. 3) was approved by the Adjudicating Authority on 27.03.2019. The approved resolution plan included provisions for roll-over/issuance of Bank Guarantees (BGs) and Letter of Credits (LCs) by the Appellant Banks, who were assenting Financial Creditors. A Non-Fund Based Facility Agreement (NFB Agreement) was entered into between the Appellants (Non-Fund Based Lenders) and the Corporate Debtor, outlining terms for NFB limits. The 'Closing Date' was achieved on 09.11.2021, by which proposed shareholders/investors infused Rs. 170 Cr. into the Corporate Debtor. … ## Issues and analysis ### Issue 1: Whether the Adjudicating Authority's order imposing one day simple imprisonment for contempt is … **Ratio:** Contempt proceedings, being quasi-criminal, require strict adherence to procedural … **Reasoning:** The Adjudicating Authority failed to record prima-facie satisfaction of willful … **Interpretation:** The NCLAT interpreted the legal requirements for contempt proceedings as … **Application:** The NCLAT applied these principles to the present case, finding that the … ## Parties - **Judges:** Ashok Bh…; Barun M… - **Appellants:** State Bank of…; Bank of…; +6 more - **Respondents:** Jyoti Structures…; Abhinav An…; +1 more - **Advocates:** Tushar Mehta…; Sunil Fer…; +21 more ## Timeline - **2017-07-04 — CIRP Admi…**: Corporate Debtor (Jyoti Structures Ltd.) admitted into Corporate Insolvency Resolution… - **2019-03-27 — Resolution Plan…**: Resolution plan submitted by Sharad Sanghi (Respondent No. 3) approved by the… ## 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) --- This is a preview. The full structured summary, issues, precedents and source judgment are available on CaseEase - Legal Intelligence Simplified: https://caseease.in/cases/ibc/nclat-new-delhi/state-bank-of-india-ors-vs-jyoti-structures-limited-ors-xyuli