# Mr. Snehal Kamdar (RP of Sapphire Land Development Private Limited) vs. Suraksha Asset Reconstruction Limited & Anr.

> NCLT judgment dated 2026-07-31. Citation: TCN-2026-NCLT-00749. The Corporate Insolvency Resolution Process (CIRP) was initiated against Sapphire Land…

- **Court:** NCLT
- **Order date:** 31 Jul 2026
- **Citation:** TCN-2026-NCLT-00749
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/nclt-mumbai/mr-snehal-kamdar-rp-of-sapphire-land-development-private-limited-vs-suraksha-ass-ulshn

## Summary

### Background

The Corporate Insolvency Resolution Process (CIRP) was initiated against Sapphire Land Development Private Limited on 30.04.2021. Mr. Ankur Kumar was initially appointed Interim Resolution Professional (IRP), followed by Mr. Snehal Kamdar as Resolution Professional (RP). The Committee of Creditors (CoC) comprised Suraksha Asset Reconstruction Ltd. (51.04%) and Unity Small Finance Bank Ltd. (48.96%). Due to a deadlock, the CoC failed to approve an extension of the CIRP period or the publication of Form G for Expression of Interest, leading the RP to file an application for liquidation.

## Facts

A petition under Section 7 of the Code was filed by Suraksha Asset Reconstruction Limited against Sapphire Land Development Private Limited, initiating CIRP on 30.04.2021.

Mr. Ankur Kumar was initially appointed as the Interim Resolution Professional (IRP), followed by Mr. Snehal Kamdar as the Resolution Professional (RP) on 01.06.2023.

The Committee of Creditors (CoC) was constituted with Suraksha Asset Reconstruction Limited (51.04% voting share) and Unity Small Finance Bank Limited (48.96% voting share).

The initial 180-day CIRP period expired on 06.11.2021, and no extension was approved by the CoC.

The CoC failed to approve the publication of Form G for inviting Expression of Interest from prospective resolution applicants.

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## Issues and analysis

### Issue 1: Whether the Corporate Debtor, Sapphire Land Development Private Limited, should be liquidated under …

**Ratio:** Section 33(1)(a) of the IBC mandates liquidation if no resolution plan is received before

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**Reasoning:** The CIRP commenced on 30.04.2021, and the 180-day period expired on 06.11.2021. No

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**Interpretation:** Section 33(1)(a) applies when the CIRP period expires without a resolution

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**Application:** Since the CIRP period expired without a resolution plan and no extension was

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## Parties

- **Judges:** LAKSHMI G…; Charanjeet Singh…
- **Appellants:** Snehal Kamdar (RP…
- **Respondents:** Sapphire Land…; Suraksha Asset…; +1 more
- **Other parties:** Snehal K…; Ankur K…; +2 more
- **Advocates:** Raina B…; Saurabh G…; +7 more

## Timeline

- **2021-04-30 — CIRP Init…**: Corporate Insolvency Resolution Process (CIRP) initiated against Sapphire Land…
- **2021-05-11 — Public Annou…**: Public Announcement (Form A) published in Mumbai Edition of Financial Express and…

## 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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