The subject matter of the case was the Corporate Insolvency Resolution Process.The bundle of rights on property constitute an asset under the the insolvency and bankruptcy code.

The subject matter of this case were the legal documents and agreements related to the ownership and development of a property by Energy Properties and the Corporate Debtor . The sale certificate executed by UCO Bank in 2008 under the SARFAESI Act and the Development Agreement of 2008 between Energy Properties and the Corporate Debtor created a bundle of rights and interests in favor of the Corporate Debtor. The Leave and License Agreement of 2011 further confirmed the Corporate Debtor’s rights over the property.

The court concludes that the bundle of rights and interests created in favor of the Corporate Debtor constitutes an asset under the Insolvency and Bankruptcy Code (IBC).

decided by the Supreme Court of India on 14.03.2023.


Sanjiv Narang Adv. is an Advocate on Record in the Supreme Court of India. His qualifications include an LLB from University of Delhi and a Masters degree in Personnel Management from Panjab University,Chandigarh.In his more than 3 decades of experience, he has practiced law at the District, High Court and Supreme Court levels.He also has more than a decade of experience in the field of Management. He is the author of two books namely Laws for Women in India and Innovation, Why What and How.