Real judgements, distilled

Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering, with the full judgement available as a PDF.

Frequently asked questions

Is this suitable for use in legal research and court filings?+

Legal Case Shots is built to help you quickly identify and understand relevant precedent. For citation in pleadings or filings, always verify against the full judgment PDF and current citation format (e.g., 2026 INSC ___).

How is a "lesson learnt" different from the judgment's holding?+

The holding is what the court legally decided. The lesson learnt translates that into a practical takeaway: what a lawyer should factor into case strategy or client advice as a result of this precedent.

Is the full judgment available, or just a summary?+

Both. Each case shows a distilled summary (case type, key holding, and lesson learnt) and links to the full judgment as a PDF for when you need the complete text for research or citation.

Can I filter judgments by date or case type?+

Yes. Use Advanced Filters to narrow results by decision date and by practice area, including Constitutional Law, Criminal Law, Service & Administrative Law, Family Law, Civil Property & Inheritance, and Labour & Industrial Law.

Can I search judgments by a specific judge?+

Yes. You can filter judgments by the judge or bench that decided the case, which is useful for tracking how a particular judge has reasoned on similar issues across multiple rulings.

What is Legal Case Shots?+

Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Company & Insolvency LawSupreme Court of India

Greater Noida Industrial Development Authority vs Prabhjit Singh Soni & Anr.

Not available · 2024 INSC 102Decided 12 Feb 2024
Not available
Chief Justice Dr. Dhananjaya Y. Chandrachud · Justice J.B. Pardiwala · Justice Manoj Misra

Background

Greater Noida Industrial Development Authority (GNIDA) had leased a plot of land to a company (the corporate debtor) for a residential project, with premium payable in instalments. When the company defaulted and went through the Corporate Insolvency Resolution Process (CIRP) under the IBC, GNIDA submitted a claim of about Rs. 43.4 crore as unpaid lease premium, describing itself as a financial creditor. The Resolution Professional instead treated GNIDA as an operational creditor and, GNIDA alleged, never gave it notice of Committee of Creditors (COC) meetings; the approved resolution plan incorrectly recorded that GNIDA had submitted no claim at all and allotted it a much smaller sum. GNIDA's applications to recall the approval and challenge the plan were rejected by the NCLT and NCLAT, leading to this appeal.

Decision Breakdown

The Supreme Court held that a Tribunal like the NCLT has inherent power to recall its own orders (even without an express statutory provision) where there has been a procedural defect, fraud, or a mistake prejudicing a party, and that GNIDA's recall applications were not time-barred given the sequence of notices it received. On the merits, the Court found the resolution plan legally defective under Section 30(2) of the IBC because it wrongly recorded that GNIDA had submitted no claim (when it had, with proof), failed to place GNIDA in the category of secured creditor despite its statutory charge over the debtor's assets under the U.P. Industrial Area Development Act, and did not adequately examine whether the plan, which depended on using land it didn't own, was actually feasible. The Court set aside both the NCLAT's and NCLT's orders and sent the resolution plan back to the Committee of Creditors for re-submission after fixing these defects.

Lesson Learnt

In an insolvency process, submitting a claim "with proof" is what matters: an error in which form you used to file it should not be allowed to erase your claim altogether; and if a resolution plan misstates your dues or omits your statutory security interest, that is a valid, reviewable defect even though the "commercial wisdom" of creditors on other matters is not normally open to challenge in court.

Greater Noida Industrial Development Authority vs Prabhjit Singh Soni & Anr. – Legal Case Shots | LegalAware