# CDP Ventures vs. Title Developers LLP

> NCLT judgment dated 2026-07-21. Citation: TCN-2026-NCLT-00639. CDP Ventures, an Operational Creditor, filed an application under Section 9 of the Insolvency…

- **Court:** NCLT
- **Order date:** 21 Jul 2026
- **Citation:** TCN-2026-NCLT-00639
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/nclt-mumbai/cdp-ventures-vs-title-developers-llp-8k3ts

## Summary

### Background

CDP Ventures, an Operational Creditor, filed an application under Section 9 of the Insolvency and Bankruptcy Code, 2016 (IBC) against Title Developers LLP, the Corporate Debtor, for initiating Corporate Insolvency Resolution Process (CIRP). The application was based on an outstanding operational debt of Rs. 1,22,44,788.32/-, which included a principal amount of Rs. 1,05,05,163.32/- and interest of Rs. 17,39,625/-. This debt arose from a construction contract for the 'Sabari Gayatri' project, which the Applicant completed. The Corporate Debtor had acknowledged the debt through emails seeking time for payment and signed Confirmations of Accounts, but failed to clear the dues after receiving a statutory Demand Notice.

## Facts

CDP Ventures (Applicant/Operational Creditor) filed C.P.(IB) No.515/MB/2025 under Section 9 of the IBC against Title Developers LLP (Corporate Debtor).

The application was filed on 24.02.2025.

Mr. Paresh Patel, a Partner of CDP Ventures, was authorized to initiate CIRP.

CDP Ventures is a Partnership Firm registered on 12.04.2016, engaged in construction.

Title Developers LLP is a Limited Liability Partnership incorporated on 22.07.2015, engaged in real estate, having built projects like Sabari Gayathri and Sabari Horizon.

Mrs. Palak Swapnil Desai was proposed as IRP, with her AFA valid till 30.06.2027.

The total amount claimed in default by the Applicant is Rs. 1,22,44,788.32/-, comprising a principal amount of Rs. 1,05,05,163.32/- and interest of Rs. 17,39,625/-.

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## Issues and analysis

### Issue 1: Whether the application under Section 9 of the IBC is maintainable despite the absence of a …

**Ratio:** The requirement under Section 9(3)(c) of the IBC for a certificate from the financial

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**Reasoning:** The Hon'ble Supreme Court in *Macquarie Bank Limited v. Shilpi Cable Technologies Ltd.*

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**Interpretation:** Procedural requirements, if not explicitly mandatory, should not hinder the

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**Application:** The Corporate Debtor's objection on this ground is devoid of merit, as the

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## Parties

- **Judges:** NILESH S…; SAMEER…
- **Appellants:** CDP Ven…
- **Respondents:** Title Developers…; Title Developers…
- **Other parties:** Palak Swapnil…
- **Advocates:** Aniruth Purusotham…; KunalKa…; +2 more

## Timeline

- **2021-01-11 — Contract Agreement…**: A Contract Agreement was executed between Title Developers LLP (CD) and CDP Ventures…
- **2022-04-01 — Confirmation of…**: Title Developers LLP (CD) issued a Confirmation of Accounts acknowledging outstanding…

## Legal provisions

- [Insolvency and Bankruptcy Code, 2016, Section 9 — Application for initiation of corporate insolvency…](https://caseease.in/legal-provisions/insolvency-and-bankruptcy-code-2016/section-9)

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