# Reliance Alpha Services Private Limited vs. Prime Focus Limited

> NCLT judgment dated 6 May 2026. Citation: TCN-2026-NCLT-00492. Reliance Alpha Services Private Limited (Financial Creditor) filed an application under Section…

- **Court:** NCLT
- **Order date:** 6 May 2026
- **Citation:** TCN-2026-NCLT-00492
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/nclt-kolkata/reliance-alpha-services-private-limited-vs-prime-focus-limited-lk8l8

## Summary

### Background

Reliance Alpha Services Private Limited (Financial Creditor) filed an application under Section 7 of the Insolvency and Bankruptcy Code, 2016 (IBC) to initiate the Corporate Insolvency Resolution Process (CIRP) against M/s. Prime Focus Limited (Corporate Debtor). The Financial Creditor claimed a default of Rs. 353,79,74,505/- (including a principal amount of Rs. 200 crores) arising from a loan agreement. This loan formalized a debt amount that the Corporate Debtor had assumed from Reliance Mediaworks Limited (RMWL) under a Business Transfer Agreement (BTA). The Corporate Debtor contested the application, arguing there was no actual disbursement of money, the liability was contingent on unfulfilled asset transfers, and that the matter involved a pre-existing contractual

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## Facts

Reliance Alpha Services Private Limited (Financial Creditor) filed an application under Section 7 of the IBC against M/s. Prime Focus Limited (Corporate Debtor).

The application seeks to initiate Corporate Insolvency Resolution Process (CIRP), appoint an Interim Resolution Professional (IRP), and initiate a moratorium against the Corporate Debtor.

The total amount claimed in default by the Financial Creditor is Rs. 353,79,74,505/-, with a principal amount of Rs. 200,00,00,000/-.

The stated date of default is 01.12.2021.

A sum of Rs. 200 crores was disbursed by the Applicant to the Respondent between March 2015 and March 2017.

Mr. Namit Malhotra, a promoter of the Corporate Debtor, executed a Personal Guarantee dated 25.05.2021 in favour of the Financial Creditor.

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## Issues and analysis

### Issue 1: Whether the debt claimed by Reliance Alpha Services Private Limited against Prime Focus Limited …

**Ratio:** Section 5(8) of the IBC defines "financial debt" as a debt, along with interest

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**Reasoning:** The NCLT found that the original Inter-Corporate Deposit (ICD) agreement between the

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**Interpretation:** The court interpreted the sequence of transactions – an initial ICD to RMWL,

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**Application:** Despite the Corporate Debtor's argument that no direct disbursement occurred to

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## Parties

- **Judges:** NILESH S…; SAMEER…
- **Appellants:** Reliance Alpha…
- **Respondents:** Prime Focus…
- **Other parties:** Insolvency and…; Corporate…; +9 more

## Timeline

- **2014-11-19 — Business Transfer…**: A Business Transfer Agreement (BTA) was executed between Prime Focus Limited (Corporate…
- **2015-03-01 — Loan Disbursement…**: Start of the period during which Rs. 200 crores was disbursed by the Applicant to the…

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