# In the matter of Frost International Limited

> NCLT judgment dated 2026-01-12. Citation: TCN-2026-NCLT-00074. 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-00074
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/nclt-mumbai/frost-international-limited-e328c0d4

## 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. The applicant sought to exclude the PI from the Corporate Debtor's assets and direct the Resolution Professional to offer the PI to the Applicant.

## Facts

The application IA 4589 of 2025 was filed on 4.9.2025 by Pan India Consultants Private Limited in the CIRP of Frost International Limited.

The CIRP commenced on February 9, 2023, pursuant to an order passed by the Tribunal u/s 7 of the Code on an application filed by Bank of India.

The Applicant and the Corporate Debtor hold Participating Interest (“PI”) in the Oil Block in the ratio as specified in Article 3 of the JOA, being 20% and 80%, respectively, at the time of award.

The applicant sought to exclude the PI from the Corporate Debtor's assets and direct the Resolution Professional to offer the PI to the Applicant.

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

…

## 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

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

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

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**Application:** The Tribunal held that the PI in Oil Block constitutes assets of the Corporate

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## 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 this Tribunal u/s 7 of the Code on an…
- **2023-04-10 — Form G I…**: The RP had issued Form G…

## 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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