# Small Industries Development Bank of India vs. Dr. Smiths Biotech Private Limited

> NCLT judgment dated 2026-09-23. Citation: TCN-2026-NCLT-01043. Small Industries Development Bank of India (Financial Creditor) initiated Corporate Insolvency…

- **Court:** NCLT
- **Order date:** 23 Sept 2026
- **Citation:** TCN-2026-NCLT-01043
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/nclt-mumbai/small-industries-development-bank-of-india-vs-dr-smiths-biotech-private-limited-pwji4

## Summary

### Background

Small Industries Development Bank of India (Financial Creditor) initiated Corporate Insolvency Resolution Process (CIRP) against Dr. Smiths Biotech Private Limited (Corporate Debtor) under Section 7 of the IBC. Megha Agarwal was appointed as the Resolution Professional. A Resolution Plan submitted by Ananta Medicare Limited was approved by the Committee of Creditors with 100% voting share. The RP filed an application (I.A. (IBC) (PLAN)/6 (MB)/2026) seeking the Tribunal's approval for this plan.

## Facts

Small Industries Development Bank of India (Financial Creditor) initiated Corporate Insolvency Resolution Process (CIRP) against Dr. Smiths Biotech Private Limited (Corporate Debtor) under Section 7 of the IBC, 2016.

The CIRP was initiated on April 28, 2025, and Megha Agarwal was appointed as the Interim Resolution Professional (IRP), later confirmed as the Resolution Professional (RP).

The Committee of Creditors (CoC) was constituted on May 19, 2025, with Small Industries Development Bank of India as the sole secured financial creditor, holding 100% voting share.

Registered valuers determined the Fair Value of the Corporate Debtor's assets at Rs. 11,00,98,209.60 and the Liquidation Value at Rs. 8,31,47,172.50.

…

## Issues and analysis

### Issue 1: Whether the Resolution Plan submitted by Ananta Medicare Limited complies with the provisions of …

**Ratio:** The Resolution Professional certified that the Resolution Plan complies with all the

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**Reasoning:** The RP filed Form H and affidavits confirming compliance with various sections (e.g.,

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**Interpretation:** The NCLT relies on the RP's certification and the detailed compliance checks

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**Application:** The NCLT found the plan compliant based on the RP's certification and

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## Parties

- **Judges:** SH. HARIHARAN…; LAKSHMI G…
- **Appellants:** Small Industries…; Megha Ag…
- **Respondents:** Smiths Biotech…
- **Other parties:** EPFO…; ESIC…; +3 more
- **Advocates:** Pulkit S…; Ativ P…; +2 more

## Timeline

- **2025-04-28 — CIRP Initiation & IRP…**: Corporate Debtor admitted into CIRP upon application by Small Industries Development Bank…
- **2025-05-01 — Public Annou…**: IRP made a public announcement to…

## 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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