Separating the Grain from the Chaff: The Supreme Court on Moonshine Defences and the Existence of a "Pre-existing Dispute" under the IBC

Supreme Court

Introduction

In a judgment that reinforces the rigorous, evidence-based approach required in insolvency proceedings, the Supreme Court of India, in M/s. Saraswati Wire and Cable Industries v. Mohammad Moinuddin Khan & Ors. (Civil Appeal No. 12261 of 2024), delivered on December 10, 2025, has set aside an order of the National Company Law Appellate Tribunal (NCLAT) and restored the order of the National Company Law Tribunal (NCLT) admitting a petition under Section 9 of the Insolvency and Bankruptcy Code, 2016 (IBC). The Court, comprising Justices Sanjay Kumar and Alok Aradhe, meticulously analyzed the concept of a "pre-existing dispute" and distinguished between a genuine, substantive defence and a "moonshine" defence aimed solely at derailing the Corporate Insolvency Resolution Process (CIRP).

This judgment serves as a critical reminder of the adjudicatory discipline demanded by the IBC’s timeline-driven framework. It underscores that while the law protects corporate debtors from being forced into insolvency over a bona fide disputed debt, it does not permit the process to be thwarted by spurious, hypothetical, or illusory claims raised as an afterthought. The decision provides a masterclass in applying the legal principles laid down in Mobilox Innovations and subsequent rulings, emphasizing that the adjudicating authority must actively sift through the material to "separate the grain from the chaff."

Factual Matrix and Procedural Journey

The appellant, M/s. Saraswati Wire and Cable Industries (the Firm), is a registered partnership firm and an operational creditor. The Corporate Debtor (CD), Dhanlaxmi Electricals Private Limited, is a licensed engineering company that had placed purchase orders with the Firm for the supply of pipes and cables. The parties maintained a running account.

The genesis of the dispute lies in the following sequence of events:

1.  Running Account and Confirmation: On July 31, 2021, the Firm emailed its ledger account to the CD seeking confirmation. On August 4, 2021, the CD’s Accounts Manager replied, raising only three points of difference pertaining to two debit notes and one voucher from November 2018. Crucially, the CD attached its own signed ledger account for the period April 1, 2017, to April 1, 2021, which showed a closing debit balance of ₹2,49,93,690.80 payable to the Firm. A subsequent ledger from April 1, 2020, to March 30, 2022, reflected an opening balance of this same amount, reduced by payments totalling ₹70 lakh made in mid-2020, resulting in a debit balance of ₹1,79,93,690.80.

2.  Demand Notice and Reply: On August 25, 2021, the Firm issued a statutory demand notice under Section 8 of the IBC for ₹1,79,93,691 along with interest. A reply was sent on November 20, 2021, by the CD’s Technical Director. This reply, for the first time, raised disputes regarding:

 a. Non-supply against two specific invoices (No. 203 & 205) totalling approximately ₹57 lakh.

 b. Supply of sub-standard and short-supplied cables, leading to a counterclaim of ₹67,96,800.

 c. Financial losses and threat of blacklisting from a client (MSEDCL).

3. Crucial Overlooked Fact – A Pre-existing CIRP: Unbeknownst to the NCLAT during its later appraisal, a separate CIRP against the same CD had already been initiated on September 6, 2021, on an application by another operational creditor. The Firm had consequently submitted its claim to the Interim Resolution Professional (IRP) of that CIRP on November 9, 2021. The IRP, in a letter dated November 19, 2021, vaguely referenced issues of sub-standard cables and short supply (citing a 2018 email) but provided no details. The CD’s Technical Director’s reply of November 20, 2021, was thus sent when the CD was under the management of the IRP, and the director himself was suspended, rendering his authority to reply questionable.

4. Withdrawal and Fresh Application: The first CIRP was later settled, and a withdrawal application under Section 12A was filed by its IRP. Upon becoming aware of this development, the Firm filed its own Section 9 application before the NCLT on February 10, 2023. The CD defaulted in filing its reply before the NCLT.

5. NCLT Admits the Petition: The NCLT, Mumbai Bench-IV, admitted the petition on December 6, 2023. It relied heavily on the CD’s own ledger account confirming the debt and noted the telling fact that the CD had paid an additional ₹61 lakh to the Firm after the issuance of the Section 8 demand notice and the disputed replies, which negated the assertion of a serious pre-existing dispute.

6. NCLAT Sets Aside Admission: The NCLAT, on appeal by a suspended director of the CD, reversed the NCLT’s order. It held that a pre-existing dispute existed, referencing the 2018-19 correspondence. It also drew an adverse inference from the Firm’s delay in filing the Section 9 application (from August 2021 to February 2023), interpreting it as evidence of ongoing disputes.

7. Supreme Court’s Intervention: The Supreme Court found the NCLAT’s reasoning flawed on multiple counts, both factual and legal, leading to the present appeal.

Legal Principles Reiterated: The Test for a "Pre-existing Dispute"

Before delving into its factual analysis, the Supreme Court reaffirmed the settled legal position governing the admission of an operational creditor’s application under Section 9 of the IBC. The cornerstone remains the test laid down in Mobilox Innovations Private Limited v. Kirusa Software Private Limited (2018) 1 SCC 353:

1.  The adjudicating authority must determine:

a. The existence of an "operational debt";

b. That the documentary evidence furnished shows the debt is due and payable and has not been paid; and

c. That no "dispute" existed prior to the receipt of the demand notice or that no suit or arbitration proceedings are pending in relation to such a dispute.

2. The Court in Mobilox cautioned that the defence of a pre-existing dispute must be examined to reject a "spurious defence which is mere bluster." The authority does not need to be satisfied that the defence is likely to succeed, but it must ascertain whether the dispute is "truly existing in fact and is not spurious, hypothetical or illusory."

The Court traced this principle back to the pre-IBC era of winding-up petitions under the Companies Act, 1956. In Amalgamated Commercial Traders (P.) Ltd. v. A.C.K. Krishnaswami and Madhusudan Gordhandas & Co. v. Madhu Woollen Industries Pvt. Ltd., it was held that a winding-up petition is not a legitimate means to enforce a debt that is bona fide disputed. The defence, however, must be "substantial and not mere moonshine."

The Court then connected this lineage to the IBC regime, citing the three-judge bench decision in Inclus Biotech Private Limited v. Kotak India Venture Fund and Tata Consultancy Services Limited v. SK Wheels Private Limited. These judgments emphasize that the adjudicating authority has a duty to examine the material placed by both the creditor and the debtor to determine if a default has occurred. The process cannot be defeated by a corporate debtor raising a "moonshine defence only to delay the process."

The synthesized legal standard, therefore, is: The adjudicating authority must actively examine the evidence to determine if the alleged dispute is bona fide, substantial, and pre-existing, or merely a moonshine defence raised to obstruct the CIRP.

Application of Law to Facts: Deconstructing the "Moonshine" Defence

The Supreme Court applied this stringent standard to the facts and found the CD’s defence utterly lacking in substance. Its analysis provides a blueprint for identifying a spurious dispute.

1. The Overwhelming Weight of the CD’s Own Admission:

The most damning evidence against the CD was its own ledger account, signed and communicated on August 4, 2021. This document was an unambiguous admission of a debt of ₹2.49 crore, later acknowledged as ₹1.79 crore after accounting for payments. The Court held that this contemporaneous commercial record, prepared in the ordinary course of business, carried far greater evidentiary value than belated, unsupported allegations raised in a reply to a demand notice. The NCLAT erred grievously in brushing this aside.

2. Conduct Inconsistent with a Genuine Dispute:

The Court applied the principle that actions speak louder than words. The CD’s conduct was completely at odds with its claim of a serious, pre-existing dispute:

a. Continued Payments: The CD made substantial payments (₹70 lakh) in 2020 after the alleged issues in 2018-19 arose.

b. Payments Post-Demand Notice: Most significantly, the CD paid an additional ₹61 lakh after receiving the Section 8 demand notice and after sending its disputed reply in November 2021. The Court logically reasoned that a party genuinely aggrieved by sub-standard goods, short supply, and non-supply would withhold payment, not continue to pay crores of rupees. This conduct "clearly negated a pre-existing dispute."

3. The Belated and Inflated Nature of the Counterclaims:

The Court scrutinized the specific allegations and found them evolving, unsubstantiated, and implausible:

a. Non-supply Invoices (203 & 205): The CD claimed no supplies were made against these invoices from late 2019. The Firm produced the delivery challan, e-way bill, tax invoice, and transport bill for the consignments. The Court found it "hardly believable" that the Firm would have fabricated these detailed transport and tax documents in 2019 in anticipation of litigation years later. The CD’s new argument regarding truck weight was dismissed as a belated, desperate clarification.

b. Short/Faulty Supply: The alleged short supply morphed from approximately 20,000 meters mentioned in a July 2019 email to a dramatic 80 kilometres claimed in the November 2021 reply. The CD provided no explanation for this 400% inflation or any material to substantiate the revised figure or the quantified counterclaim of ₹67,96,800.

c. Sub-standard Quality & Blacklisting Threat: The allegation of suffering huge losses and facing blacklisting from MSEDCL was entirely unsupported by any documentary evidence such as the client’s complaint, test reports, or correspondence regarding the alleged faulty material.

4. The Invalidity of the Reply Itself:

The Court noted a critical jurisdictional flaw: the reply disputing the debt was sent by the CD’s suspended Technical Director on November 20, 2021. By this date, a CIRP against the CD was already underway (since September 6, 2021), and the management of the CD had vested in the IRP. The suspended director had no authority to represent the CD or acknowledge or dispute debts on its behalf. This rendered the reply legally infirm.

5. Explaining the Delay in Filing:

The Court corrected the NCLAT’s erroneous inference drawn from the Firm’s delay in filing its Section 9 application. The delay was not due to ongoing negotiations or disputes but because a separate CIRP was already pending against the CD. The Firm had rightfully submitted its claim in that process. It was only upon learning of the application to withdraw that CIRP that the Firm initiated its own proceeding. This delay was thus procedurally justified and could not be held against the Firm.

Conclusion and Implications: A Victory for Procedural Rigor

Allowing the appeal, the Supreme Court set aside the NCLAT’s judgment and restored the NCLT’s order admitting the Section 9 petition. The Court held that the defence of a pre-existing dispute was "mere moonshine and had no credible basis or foundation" and that the attempt to project it was "mere bluster."

This judgment has significant implications for the conduct of IBC proceedings:

1. Primacy of Contemporary Documentary Evidence: The case elevates the status of internally maintained ledger accounts and admission of debt by the corporate debtor as powerful, if not decisive, evidence against a subsequently raised dispute. Adjudicating authorities must give due weight to such documents.

2. Conduct as an Indicator of Bona Fides: Continued payments by a debtor, especially after a demand notice, will be heavily scrutinized and will severely undermine a later claim of a serious, pre-existing dispute.

3. Duty of Active Adjudication: The NCLT/NCLAT cannot take defences at face value. They have a positive duty to "advert to the material," examine inconsistencies, demand substantiation, and separate genuine disputes from spurious ones. The standard is not a full trial on merits, but a reasoned evaluation of whether the dispute is prima facie substantial.

4. No Shelter for Moonshine Defences: The judgment firmly shuts the door on tactics aimed at exploiting the "pre-existing dispute" threshold to cause unwarranted delay. Defences must be specific, substantiated, and consistent. Vague, evolving, and unsubstantiated allegations will be dismissed.

5. Awareness of Overall Proceedings: The Supreme Court criticized the NCLAT for being "kept in the dark" about the other CIRP. This highlights the need for appellate tribunals to ensure a complete factual record is before them, as contextual facts can completely alter the interpretation of a party’s conduct (like the delay in filing).

In essence, Saraswati Wire and Cable Industries v. Mohammad Moinuddin Khan reaffirms that the IBC is a serious mechanism for resolving insolvency, not a battleground for tactical litigation. It empowers operational creditors with genuine claims while protecting corporate debtors from frivolous triggers, provided they can demonstrate a dispute that is real, not a mere shadow. The judgment is a clarion call for adjudicating authorities to be vigilant gatekeepers, ensuring the swift and efficient resolution envisioned by the Code is not compromised by defences made of moonshine.

Case Cited: M/s. Saraswati Wire and Cable Industries v. Mohammad Moinuddin Khan & Ors., Civil Appeal No. 12261 of 2024, Supreme Court of India, Decided on December 10, 2025.

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