Submit Article
Legal Analysis. Regulatory Intelligence. Jurisprudence.
Search articles, case studies, legal topics...
IBBI

Why India's CIRP Funnel Narrows: From 6,210 Admissions to 1,681 Plans

The Corporate Insolvency Resolution Process was designed as a clean pipe from default to plan. Across 20,314 CIRP orders the funnel narrows hard at every joint.

300 wpm
0%
Chunk
Theme
Font

For every 100 admissions, 27 plans, 18 liquidations, 20 settlements, and a third still inside

The Corporate Insolvency Resolution Process — CIRP, in IBC shorthand — is the part of the Code most often described and least often delivered. Section 7 (or 9, or 10) brings a debtor into CIRP through admission. Section 14 freezes the world around it. Section 22 puts a Resolution Professional in charge. Section 30 builds a plan. Section 31 approves it. Section 33, if anything goes wrong, orders liquidation.

Read that paragraph fast and the Code looks like a clean pipe. Read it slow, against the corpus, and what one sees is a funnel that narrows hard at every joint.

What happens to 100 companies that walk into CIRP?

Stage Orders, 2017–2024 Of admissions
Admitted (CIRP begins) 6,210 100%
Withdrawn (Section 12A settlement) 1,268 20.4%
Plan approved (Section 31) 1,665 26.8%
Liquidation ordered (Section 33) 1,139 18.3%
Rejected / dismissed 2,508 40.4%

The rows do not sum to 100% — the funnel is not closed. Many admissions in 2022-24 are still in flight; a single corporate debtor may show up across multiple rows in different years (admitted in 2019, plan approved in 2022); the categories are not mutually exclusive in the data the way they are in life. But the rough geometry is clear.

For every 100 cases admitted into CIRP, about 27 end in a resolution plan, 18 in liquidation, 20 in a Section 12A withdrawal, and the remaining third sit in some intermediate state of admission, dismissal, or pending decision.

Read another way: the Code’s preference for resolution over liquidation is visible, but barely. Plans-to-liquidations runs 1.46 to 1. It is not the 3-to-1 ratio the Bankruptcy Law Reforms Committee report imagined in 2015.

Which year did CIRP admissions really take off — and why did 2024 settlements collapse?

Year Admitted Plan approved Liquidation Withdrawn
2017 418 22 28 54
2018 777 101 166 41
2019 1,059 234 214 272
2020 554 160 136 182
2021 720 237 171 220
2022 1,174 237 164 296
2023 879 386 160 144
2024 625 297 105 59

A few things stand out from that table.

2019 was the year of admissions. The IBC’s first real volume year, with the 2018 amendments bedded in and the appellate doctrine settled.

2023 was the year of plan approvals. 386 plans, more than in any other year. Many were 2019/2020 admissions catching up after the Section 10A pandemic freeze.

Liquidations peaked in 2019 (214) and have declined every year since. The 2024 figure (105) is roughly half the peak. Either resolution outcomes are improving, or the cases that would have liquidated are being filtered out at admission, or both.

Withdrawals collapsed in 2024 to 59 — the lowest since 2017. That collapse has a single cause: a Supreme Court ruling in October 2024 that tightened Section 12A. The story is the third feature in this issue — The Court Case That Shut BYJU’s Escape Hatch.

What is the Section 12A door — and what does it now require?

Section 12A was inserted by the 2018 amendment to give CIRP a controlled exit ramp. After admission, the applicant can withdraw — with the consent of 90% of the CoC. It is the IBC’s reverse-gear: the mechanism by which a corporate debtor and its lender can talk their way out of CIRP if both want to.

The Section appears in 1,373 orders. As an outcome, withdrawn shows up 1,268 times.

Until 2024, withdrawals were running 144–296 per year. Then, in GLAS Trust Company LLC v. BYJU Raveendran (SC, 23 Oct 2024), the Supreme Court intervened: a withdrawal under Section 12A cannot be effected after the CoC is constituted unless the withdrawal goes through the CoC with the requisite 90% vote. The case was, as it happens, BYJU’s — which had attempted a back-channel settlement with one creditor (BCCI) before the CoC voted.

The data shows the aftermath: withdrawals in 2024 fell to 59. GLAS Trust did not change the statute, but it changed the incentives. After October 2024, applicants who had previously relied on out-of-court settlements to dodge CIRP found that route closed.

A representative withdrawal precedent — Brilliant Alloys Pvt. Ltd. v. Mr. S. Rajagopal — is cited 54 times across this corpus as the authority for the proposition that 12A withdrawals filed pre-constitution of the CoC operate on a different footing.

Who are the ten people doing India’s heaviest IBC resolution work?

A handful of insolvency professionals account for a disproportionate share of the visible work. The top ten, by number of orders in which they appear as RP:

Rank Name Orders
1 Anil Kohli 39
2 Jalesh Kumar Grover 23
3 Nilesh Sharma 22
3 Anish Niranjan Nanavaty 22
5 Murali Mohan Chevuturi 21
6 Ravindra Beleyur 20
7 Sumit Binani 18
7 Abhishek Anand 18
9 Avishek Gupta 17
9 Maligi Madhusudhana Reddy 17

A few names are recognisable from the bigger CIRPs of the recent past.

Anish Niranjan Nanavaty was the RP for Dewan Housing Finance Corporation Ltd. (DHFL) — the first NBFC ever resolved under IBC. Sumit Binani has appeared in the Central Transmission Utility matters and the Binani Cement saga. Ravindra Beleyur handled the Anrak Aluminium liquidation, among others. Abhishek Anand appears 18 times here as RP — and as the respondent in a 2024 IBBI Disciplinary Committee order; see Policing the Profession.

The top-10 RPs together account for 217 orders — barely 3.5% of all CIRP orders. The long tail is very long. There are several thousand IPs who appear in the corpus exactly once or twice. The IBC profession is structured, in this data, like a power-law curve: a small head doing a lot of work, a long tail doing very little.

Why is the statutory 330-day deadline an open joke?

Section 12(3) of the Code sets a hard outer limit of 330 days for CIRP, inclusive of any extensions and any time consumed by litigation. The 270-day inner limit was, until 2019, supposed to be inviolable; Essar Steel loosened it; the 2019 amendment loosened it further.

How long, in practice, did the cases in this corpus take?

For the subset of CIRP cases where both admission and plan-approval dates are clean, the median time from admission to plan approval is roughly 2.4 years — comfortably past the statutory 330 days.

The Sintex-BAPL case in How a CIRP Actually Works is fairly typical: admitted in 2020, plan approved in March 2023. Three years and change. Faster than DHFL (about three and a half years), faster than Jaypee Infratech (about six), slower than several of the smaller MSME CIRPs.

The 330-day clock is, by any honest reading of the data, a fiction. It is observed in form — orders routinely contain a sentence explaining why the extension is permissible — and breached in substance. This is one of the IBC’s more uncomfortable truths, and it is not getting better with time.

What did the average CoC actually vote when it approved a plan?

587 CoC voting percentages have been recorded across the eight years of orders examined for this issue. Across those records:

  • Average voting share in favour: 86.3%
  • Statutory minimum (Section 30(4)): 66%
  • Range: from 0.01% (plans that failed catastrophically at the CoC stage) to 100% (unanimous)

The 14-point gap between the average (86.3%) and unanimity (100%) is the shape of CoC dissent in Indian insolvency. When a plan gets approved, it generally gets through by a comfortable super-majority — but not without losers. Those losers — the dissenting financial creditors — are the constituency Maharashtra Seamless and Kalpraj Dharamshi spent the last five years writing doctrine for.


What this funnel really tells us

Three things.

First, the system admits more than it resolves. The CIRP funnel narrows from 6,210 admissions to 1,665 plans, and the gap is not fully accounted for by liquidations and withdrawals. Several thousand cases sit, somewhere in the corpus, in a holding pattern of dismissals, rejections, and intermediate orders. CIRP is not, as the rhetoric of 2016 had it, a sieve that quickly sorts viable from non-viable businesses. It is a slow filter.

Second, resolution and liquidation are running roughly 1.5 to 1. The ratio improved in 2023-24, but the structural number, across the whole eight-year run, is 1.46 plans for every liquidation. The Code’s resolution preference is narrow.

Third, the supply of resolution professionals is concentrated at the top and very thin in the middle. Ten IPs handle a noticeable share of all visible CIRPs. Beneath them is a very long tail of one- and two-case practitioners. Whether that distribution is a strength or a weakness of the profession — economies of expertise versus single points of failure — is one of the harder governance questions the IBC has produced.


Read next: Two Doors, Two Outcomeswhy Section 7 financial creditors are 60% more likely than Section 9 operational creditors to walk out with a plan.

Written by Sushant Shukla
1.5×

More in

Legal Wires

Legal Wires

Stay ahead of the legal curve. Get expert analysis and regulatory updates natively delivered to your inbox.

Success! Please check your inbox and click the link to confirm your subscription.