# In the matter of Reliance Entertainment Studios Pvt. Ltd.

> NCLT judgment dated 2025-08-04. Citation: TCN-2025-NCLT-01301. Dream Warrior Pictures, an Operational Creditor, filed an application under Section 9 of the…

- **Court:** NCLT
- **Order date:** 4 Aug 2025
- **Citation:** TCN-2025-NCLT-01301
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/nclt-mumbai/reliance-entertainment-studios-pvt-ltd-2b3654c8

## Summary

### Background

Dream Warrior Pictures, an Operational Creditor, filed an application under Section 9 of the IBC to initiate CIRP against Reliance Entertainment Studios Pvt. Ltd. The application was based on a Remake Rights Agreement where Dream Warrior Pictures assigned remake rights of their film 'Kaithi' to Reliance Entertainment Studios.

## Facts

Dream Warrior Pictures released the film 'Kaithi' and owned the copyright.

A Remake Rights Agreement was executed between Dream Warrior Pictures and Reliance Entertainment Studios for a Hindi remake.

Dream Warrior Pictures assigned 50% of remake rights to Reliance Entertainment Studios and granted the right to appoint Ajay Devgn FFilm Productions LLP as an Additional Producer.

The total amount claimed to be in default was Rs. 5,93,36,438/-.

The date of default was mentioned as 29.04.2023 for Assignment Fees and 29.05.2023 for Additional Fees.

Reliance Entertainment Studios paid Rs. 1,00,00,000/- to Dream Warrior Pictures.

Dream Warrior Pictures issued a legal notice and a demand notice under Section 8 of the IBC.

…

## Issues and analysis

### Issue 1: Whether the issuance of a valid invoice is a condition precedent for payment under the Remake …

**Ratio:** Clause 4.6 of the Remake Rights Agreement specifies that payment of the consideration

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**Reasoning:** The Adjudicating Authority relied on the specific wording of the agreement, stating that

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**Interpretation:** The clause is interpreted as making the issuance of a valid invoice a condition

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**Application:** Since the Applicant did not raise a valid invoice, the Corporate Debtor's

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## Parties

- **Judges:** SAMEER…; NILESH S…
- **Appellants:** Dream Warrior…
- **Respondents:** Reliance Entertain…
- **Advocates:** Shyam Ka…; Aayush Tai…; +7 more

## Timeline

- **2025-01-28 — Application…**: C.P.(IB) No.156/MB/2025 filed…
- **2025-03-06 — Interim…**: Tribunal issued an interim order regarding…

## Legal provisions

- [Insolvency and Bankruptcy Code, 2016, Section 8 — Insolvency resolution by operational creditor](https://caseease.in/legal-provisions/insolvency-and-bankruptcy-code-2016/section-8)

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