IBBI Suspends Insolvency Professional Pankaj Narang for Two Years Over CIRP Violations and Governance Lapses

Facts and Findings

The Insolvency and Bankruptcy Board of India (IBBI), through its Disciplinary Committee, has suspended the registration of insolvency professional Mr. Pankaj Narang for a period of two years for multiple contraventions during the Corporate Insolvency Resolution Process (CIRP) of J.B.K Developers Private Limited.

The proceedings arose from a complaint received in March 2025, followed by an investigation under Section 218 of the Insolvency and Bankruptcy Code, 2016. A Show Cause Notice was issued in September 2025 alleging violations of statutory duties and professional conduct obligations.

The Disciplinary Committee found that Mr. Narang failed to place a mandatory agenda for his replacement before the Committee of Creditors (CoC), despite a requisition from homebuyers representing more than 33% of voting rights. The Committee held that Regulation 18(3) of the CIRP Regulations imposes a mandatory obligation, leaving no discretion once the statutory threshold is met. The RP’s failure to verify voting share claims transparently, coupled with misrecording of CoC minutes regarding prior consideration of such agenda, was treated as a serious lapse.

Further, the Committee held that Mr. Narang failed to comply with GST requirements applicable during CIRP. Despite statutory obligation to obtain GST registration within 30 days of appointment, no registration was secured. The explanation citing lack of KYC documents and non-cooperation of promoters was rejected, particularly in light of available remedies under the Code and special GST procedures applicable to CIRP cases.

The Committee also noted failure to raise invoices for professional fees, in violation of the Code of Conduct, and observed that such obligation cannot be deferred on grounds of GST-related uncertainty.

Additionally, while multiple lists of creditors were published on the corporate debtor’s website, updated lists were not consistently filed on the IBBI portal as required. This was treated as a technical contravention without evidence of stakeholder prejudice.

Considering the cumulative violations, the IBBI ordered suspension of registration for two years, effective after 30 days.