# M/S.LAMBA EXPORTS PVT. LTD. vs. M/S.DHIR GLOBAL INDUSTRIES PVT. LTD. AND ORS.

> SC judgment dated 2026-03-23. Citation: TCN-2026-SC-00065. M/s. Lamba Exports Pvt. Ltd. (applicant/petitioner) filed a Miscellaneous Application (MA) in the…

- **Court:** SC
- **Order date:** 23 Mar 2026
- **Citation:** TCN-2026-SC-00065
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/supreme-court-of-india/mslamba-exports-pvt-ltd-vs-msdhir-global-industries-pvt-ltd-and-ors-a8g5e

## Summary

### Background

M/s. Lamba Exports Pvt. Ltd. (applicant/petitioner) filed a Miscellaneous Application (MA) in the Supreme Court, seeking to recall an order dated 25.02.2025 which had dismissed their Special Leave Petition (SLP). The SLP challenged a High Court order that had upheld the setting aside of an interim injunction in a civil suit for specific performance of an Agreement to Sell. The MA was based on "subsequent developments" related to insolvency proceedings against M/s. Dhir Global Industries Pvt. Ltd. (Respondent No. 1), including a One Time Settlement (OTS) and withdrawal of the Corporate Insolvency Resolution Process (CIRP) under Section 12A of the IBC. The applicant alleged non-disclosure of these events and fraud.

## Facts

Miscellaneous Application No. 1256 of 2025 (MA) was filed in Special Leave Petition (Civil) No. 12264 of 2024 (SLP) seeking recall of an order dated 25.02.2025 passed by the Supreme Court.

The SLP was filed against a judgment and order dated 06.05.2024 passed by the High Court of Punjab and Haryana in Civil Revision No. 3916 of 2022, which had dismissed the applicant's revision petition.

The MA's basis for recall includes alleged non-disclosure of a One Time Settlement (OTS) proposal, eventual settlement between the secured creditor and the corporate debtor, and withdrawal of the Corporate Insolvency Resolution Process (CIRP) under Section 12A of the Insolvency and Bankruptcy Code, 2016 (IBC).

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## Issues and analysis

### Issue 1: Whether a Miscellaneous Application seeking recall of a dismissed Special Leave Petition is …

**Ratio:** A post-disposal miscellaneous application is maintainable only in narrow, rare

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**Reasoning:** The Court becomes functus officio once a matter is disposed of. The order dismissing the

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**Interpretation:** The Court strictly interprets the scope of miscellaneous applications filed

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**Application:** In this case, the MA did not fall within the recognized narrow exceptions for

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## Parties

- **Judges:** VIKRAM…; SANDEEP…
- **Appellants:** M/S.LAMBA EXPORTS…
- **Respondents:** M/S.DHIR GLOBAL…
- **Other parties:** Committee of…; Respondent No. 4…

## Timeline

- **2021-08-13 — Agreement t…**: An Agreement to Sell was executed between the parties concerning the subject property…
- **2022-03-25 — Legal Notice t…**: Respondent Nos. 1 to 3 sought to resile from the Agreement to Sell by legal notice,…

## Legal provisions

- [Insolvency and Bankruptcy Code, 2016, Section 12A — (1) Subject to sub](https://caseease.in/legal-provisions/insolvency-and-bankruptcy-code-2016/section-12a)

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