# In the matter of Frost International Limited

> NCLT judgment dated 2026-01-12. Citation: TCN-2026-NCLT-00067. The application IA 4589 of 2025 was filed by Pan India Consultants Private Limited in the CIRP…

- **Court:** NCLT
- **Order date:** 12 Jan 2026
- **Citation:** TCN-2026-NCLT-00067
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/nclt-mumbai/frost-international-limited-4df3f48f

## Summary

### Background

The application IA 4589 of 2025 was filed by Pan India Consultants Private Limited in the CIRP of Frost International Limited, seeking a direction regarding the Participating Interest (PI) of the Corporate Debtor in an Oil Block.

## Facts

Pan India Consultants Private Limited filed IA 4589 of 2025 in the CIRP of Frost International Limited.

The CIRP commenced on February 9, 2023, following an application by Bank of India.

The applicant and the Corporate Debtor hold Participating Interest (PI) in the Oil Block.

The applicant sought a declaration that the PI is not an asset of the Corporate Debtor.

The CoC approved a resolution plan under Option I (Corporate Debtor as a whole) on November 3, 2025.

The applicant was appointed as the 'Operator' of the Oil Block.

The applicant claims a pre-emptive right to purchase the Corporate Debtor's PI.

…

## Issues and analysis

### Issue 1: Whether the PI interest in Oil Block …

**Ratio:** The bundle of rights and interests in the Oil Block acquired by the Corporate Debtor, in

…

**Reasoning:** The tribunal relied on the Supreme Court's decision in Victory Iron Works Ltd. v.

…

**Interpretation:** The rights and interests in the Oil Block held by the Corporate Debtor are

…

**Application:** The Resolution Professional is duty-bound under Section 25(2)(a) to take

…

## Parties

- **Judges:** Prabhat…; Sushil Mahadeorao…
- **Appellants:** Pan India…; BANK OF…
- **Respondents:** FROST INTERNATIONA…; Amit Chandrakant…; +2 more
- **Advocates:** Ashish M…; Amay Shiv…; +7 more

## Timeline

- **2023-02-09 — CIRP Commen…**: CIRP commenced pursuant to order passed by the Tribunal u/s 7 of the Code on an…
- **2025-06-03 — 40th CoC M…**: 6 final compliant resolution plans received…

## Legal provisions

- [Insolvency and Bankruptcy Code, 2016, Section 60(5) — Adjudicating Authority for corporate persons](https://caseease.in/legal-provisions/insolvency-and-bankruptcy-code-2016/section-60)

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