# In the matter of Samsara Energy Limited

> NCLT judgment dated 2025-11-27. Citation: TCN-2025-NCLT-01740. The case involves SREI Equipment Finance Limited as the financial creditor and Samsara Energy…

- **Court:** NCLT
- **Order date:** 27 Nov 2025
- **Citation:** TCN-2025-NCLT-01740
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/nclt-kolkata/samsara-energy-limited-340e7273

## Summary

### Background

The case involves SREI Equipment Finance Limited as the financial creditor and Samsara Energy Limited as the corporate debtor. The matter is being heard under Section 7 of the IBC.

## Facts

SREI Equipment Finance Limited initiated proceedings against Samsara Energy Limited under Section 7 of the IBC.

The Corporate Debtor's counsel stated that the reply affidavit could not be uploaded due to an incorrect email ID provided by the petitioner.

The Tribunal directed the Corporate Debtor's counsel to provide a hard copy of the reply affidavit to the Court Master.

Mr. Subrato Ghosh, an Insolvency Professional, appeared before the Tribunal in a vest (undergarment).

The Tribunal considered Mr. Ghosh's attire as contemptuous and insulting to the court.

The Tribunal issued a show cause notice to Mr. Ghosh for potential criminal contempt under Section 2(c)(i) of the Contempt of Court Act 1971.

…

## Issues and analysis

### Issue 1: Whether the appearance of an Insolvency Professional in inappropriate attire before the Tribunal …

**Ratio:** Appearing in a baniyan (vest/undershirt) before a court amounts to contempt as defined in

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**Reasoning:** The Tribunal reasoned that appearing in such attire violates basic courtroom decorum and

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**Interpretation:** The Tribunal interpreted Section 2(c)(i) of the Contempt of Court Act 1971 to

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**Application:** The Tribunal applied this interpretation to the actions of Mr. Subrato Ghosh,

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## Parties

- **Judges:** Labh S…; Rekha Kantilal…
- **Appellants:** SREI Equipment…
- **Respondents:** SAMSARA ENERGY…
- **Other parties:** Subrato…
- **Advocates:** Sankarsan…; Aditya Ka…; +6 more

## Timeline

- **2025-11-27 — Hearing…**: Order sheet of the…
- **2025-12-04 — Filing of Ha…**: Matter listed for filing of hard copy…

## Legal provisions

- [Insolvency and Bankruptcy Code, 2016, Section 7 — Initiation of corporate insolvency resolution…](https://caseease.in/legal-provisions/insolvency-and-bankruptcy-code-2016/section-7)

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