# In the matter of GLS Films Industries Private Limited vs. Chemical Suppliers India Private Limited

> SC judgment dated 2026-04-09. Citation: TCN-2026-SC-00021. The initiation of the corporate insolvency resolution process against GLS Films Industries Private…

- **Court:** SC
- **Order date:** 9 Apr 2026
- **Citation:** TCN-2026-SC-00021
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/supreme-court-of-india/gls-films-industries-private-limited-vs-chemical-suppliers-india-private-limited-62d41fc5

## Summary

### Background

The initiation of the corporate insolvency resolution process against GLS Films Industries Private Limited was initially denied by the adjudicating authority (NCLT) but reversed by the appellate authority (NCLAT). GLS Films Industries Private Limited, being the corporate debtor, appealed against the NCLAT's decision.

## Facts

Chemical Suppliers India Private Limited filed a Company Petition (IB)-792(ND) of 2021 under Section 9 of the Insolvency and Bankruptcy Code, 2016 against GLS Films Industries Private Limited.

GLS Films Industries Private Limited claimed that Chemical Suppliers India Private Limited supplied defective chemicals, leading to a pre-existing dispute.

GLS Films Industries Private Limited issued a debit note on 31.12.2021 for ₹2,42,11,648/- due to losses from defective supplies.

GLS Films Industries Private Limited lodged a police complaint on 27.09.2021 regarding the defective supplies and pressure tactics by Chemical Suppliers India Private Limited.

The NCLT initially dismissed the application, finding a plausible pre-existing dispute.

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## Issues and analysis

### Issue 1: Whether a pre-existing dispute …

**Ratio:** The adjudicating authority must satisfy itself as to the existence of a plausible

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**Reasoning:** The Supreme Court referred to Mobilox Innovations Private Limited vs. Kirusa Software

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**Interpretation:** A 'plausible dispute' requires further investigation and is not a patently

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**Application:** The Court found that the exchange of letters, debit notes, and the police

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## Parties

- **Judges:** Sanjay…; R. MAHA…
- **Respondents:** GLS Films…; Chemical Suppliers…
- **Other parties:** Ankur Agg…

## Timeline

- **2021-XX-XX — Filing of Company…**: Company Petition (IB)-792(ND) of 2021 was filed by Chemical Suppliers India Private…
- **2021-11-11 — Demand N…**: Demand notice dated 11.11.2021 was issued by Chemical Suppliers India Private Limited…

## 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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