NATIONAL COMPANY LAW APPELLATE TRIBUNAL Dismisses Appeal as Infructuous Due to Grievance Redressal. Appeal Dismissed as the Company's Name Change Resolved the Appellant's Grievance.

Tribunals: National Company Law Appellate Tribunal Bench: New Delhi
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Case Note & Summary

The case involved an appeal by Anil Dhirubhai Ambani Ventures Pvt. Ltd. against Reliance Capital Ltd. The appeal was heard by the National Company Law Appellate Tribunal on 25th September 2026. The Respondent's counsel, Shri Arun Kathpalia, submitted that the appeal had become infructuous because the grievance of the Appellant had been resolved; the company name was changed from 'Reliance Capital Ltd.' to 'IndusInd', and an affidavit confirming this change was filed on 11th September 2026. The Appellant's counsel acknowledged that there was nothing left to consider in the appeal and requested its dismissal. Consequently, the Tribunal dismissed the appeal as infructuous, stating that there were no orders as to costs and all pending interim applications were disposed of. The decision was made by Justice Mohammad Faiz Alam Khan and Member (Technical) Indevar Pandey.

Headnote

A) Company Law - Infructuous Appeal - Dismissal of Appeal - Companies Act, 2013 - The appeal was dismissed as infructuous since the grievance of the Appellant was redressed by changing the name of the company from 'Reliance Capital Ltd.' to 'IndusInd'. The Appellant's counsel conceded that nothing survives in the appeal, leading to its dismissal. Held that the appeal is dismissed as infructuous (Paras 1-3).

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Issue of Consideration

Whether the appeal should be dismissed as infructuous due to the redressal of the grievance.

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Final Decision

The appeal was dismissed as infructuous, with no orders as to costs and all pending interim applications disposed of.

Law Points

  • Infructuous appeal
  • dismissal of appeal
  • change of company name
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Case Details

2026 LawText (NCLAT) (09) 204

Company Appeal (AT) (Insolvency) No. 2263 of 2024

2026-09-25

Justice Mohammad Faiz Alam Khan, Indevar Pandey

Mr. Hasan Murtaza, Mr. Sameer Sharma, Mr. Ankit Kumar Sinha, Mr. Navneet R., Ms. Hemkrite Sinha, Mr. Arun Kathpalia, Mr. Shikhil Suri, Mr. Pranav Saigal, Ms. Trishala Trivedi, Ms. Wamika Chadha

Anil Dhirubhai Ambani Ventures Pvt. Ltd.

Reliance Capital Ltd. & Anr.

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Nature of Litigation

Appeal regarding a grievance related to the name of a company.

Remedy Sought

The Appellant sought to address a grievance regarding the company's name.

Filing Reason

The appeal was filed due to a grievance concerning the name of the company.

Previous Decisions

The grievance was redressed by changing the company name, leading to the appeal's dismissal.

Issues

Whether the appeal should be dismissed as infructuous due to the redressal of the grievance.

Submissions/Arguments

The Respondent's counsel argued that the appeal is infructuous due to the name change. The Appellant's counsel conceded that nothing survives in the appeal.

Ratio Decidendi

The appeal was dismissed as the grievance was resolved by the change of the company's name, indicating that the purpose of the appeal was no longer relevant.

Judgment Excerpts

The appeal has become infructuous as the grievance of the Appellant has been redressed. Nothing survives to be considered in the appeal and the same is dismissed as has become infructuous.

Procedural History

The appeal was filed and subsequently heard on 25th September 2026, where the grievance was found to be resolved.

Acts & Sections

  • Companies Act, 2013:
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