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Drafting Pleadings & Appearances

Appearing Before NCLAT — Appellate Practice Guide for CS 2026

VS Vikas Sharma 📅 March 25, 2026 ⏱️ 2 min read 👁️ 0 views

NCLAT Practice for Company Secretaries

CS professionals with COP have the statutory right to appear before NCLAT under Section 432 of the Companies Act, 2013. NCLAT handles appeals from: (a) NCLT orders in company law matters (Section 421), (b) NCLT orders in IBC matters (Section 61 IBC), (c) CCI orders in competition matters (Section 53B Competition Act). NCLAT Principal Bench sits in New Delhi with a Chennai Bench for southern states. CS can represent appellants and respondents — drafting appeals, filing, arguing, and handling all procedural aspects.

Filing an Appeal Before NCLAT

Limitation: Company law: 45 days. IBC: 30 days (+15 days condonable). Competition: 60 days. Form: Prescribed NCLAT forms — Form NCLAT-1 (company law appeals), Form NCLAT-2 (IBC appeals). Contents: grounds of appeal, certified copy of NCLT/CCI order, affidavit, list of documents. Filing Fee: Rs. 5,000-25,000 depending on the type. E-filing: Through NCLAT e-filing portal (efiling.nclat.nic.in) with DSC. Service: Serve copies on all respondents — file proof of service.

Appeal Procedure

(a) ADMISSION: NCLAT examines maintainability — jurisdiction, limitation, prima facie merit. (b) NOTICE: If admitted — notice to respondent with hearing date. (c) STAY: Filing does NOT auto-stay NCLT order — apply separately for stay (prima facie case, irreparable harm, balance of convenience). (d) REPLY: Respondent files reply within granted time. (e) REJOINDER: Appellant may file rejoinder. (f) ARGUMENTS: Both sides argue — appellant first. (g) ORDER: NCLAT passes reasoned order — confirming, modifying, or setting aside the NCLT/CCI order.

Key Differences — NCLT vs NCLAT Practice

FeatureNCLTNCLAT
NatureOriginal/first instanceAppellate
EvidenceTakes evidence (affidavits + oral)Generally no fresh evidence
FocusFacts and lawPrimarily law (limited fact review)
Composition1 Judicial + 1 Technical memberChairperson + multiple members
Appeal fromN/ANCLT orders → NCLAT
Further appealNCLATSupreme Court

IBC Appeals — Special Considerations

IBC matters are TIME-BOUND — NCLAT appeals must be decided quickly. Key IBC appeal issues: (a) rejection/admission of insolvency applications, (b) approval/rejection of resolution plans, (c) liquidation orders, (d) claims and distribution disputes. The 330-day CIRP timeline creates URGENCY — NCLAT prioritizes IBC appeals. CS representing in IBC appeals must: demonstrate urgency, prepare comprehensive written submissions, and be ready for early hearing dates.

Advocacy Tips for NCLAT

(a) Focus on errors: NCLAT reviews the NCLT order — identify specific ERRORS (factual, legal, procedural) in the order. Don't re-argue the entire case. (b) Written submissions: NCLAT benches rely heavily on written submissions — file a well-structured synopsis. (c) Precedent compilation: Prepare a compilation of relevant NCLAT/Supreme Court precedents with highlighted paragraphs. (d) Certified copy: Always have the certified copy of the NCLT order — NCLAT refers to it frequently. (e) Stay application: If stay is critical — prepare a strong stay application arguing all three conditions (prima facie case, irreparable harm, balance of convenience).

Disclaimer: This article is for informational purposes only and does not constitute legal or professional advice. While every effort has been made to ensure accuracy based on the latest laws and amendments, readers should consult a qualified professional before acting on any information provided. For expert assistance, contact us.

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❓ Frequently Asked Questions
What is the time limit for filing appeal before NCLAT?
Company law (Section 421): 45 DAYS. IBC (Section 61(2)): 30 DAYS (+15 days condonable — maximum 45 days total). Competition (Section 53B): 60 DAYS. The period starts from the date of the NCLT/CCI order — not from receipt of certified copy. However: time for obtaining certified copy may be excluded (analogous to Section 12 Limitation Act). Condonation of delay: NCLAT has discretion to condone if 'sufficient cause' is shown. File condonation application with the appeal if filing beyond limitation.
Does filing appeal automatically stay the NCLT order?
NO — filing an appeal does NOT automatically stay the NCLT/CCI order. The appellant must file a SEPARATE stay application. NCLAT grants stay if: (1) PRIMA FACIE CASE — the appeal has arguable merit, (2) IRREPARABLE HARM — execution of the order would cause damage that cannot be compensated later, (3) BALANCE OF CONVENIENCE — more prejudice to the appellant if stay is refused. For IBC matters: stays are RARELY granted because delays defeat the time-bound resolution process. For merger orders: stays may be granted to prevent irreversible actions.
Can NCLAT admit new evidence not presented before NCLT?
Generally NO — NCLAT is an APPELLATE body that reviews the NCLT's decision based on the SAME record. New evidence is admitted only in EXCEPTIONAL cases: (1) the evidence was NOT available at the NCLT stage despite due diligence, (2) the NCLT refused to admit relevant evidence, (3) NCLAT requires the evidence to pronounce a just decision. The appellant must file a formal application for admission of additional evidence — explaining why it was not produced earlier. NCLAT exercises discretion — additional evidence applications are scrutinized carefully.
What is the appeal chain from NCLAT?
NCLAT orders → appeal to SUPREME COURT: (1) Company law matters: Section 423 Companies Act — within 60 DAYS, (2) IBC matters: Section 62 IBC — within 60 DAYS, (3) Competition matters: Section 53T Competition Act — within 60 DAYS. The appeal to the Supreme Court is on QUESTIONS OF LAW only — not facts (unless findings are perverse). The Supreme Court may grant or refuse leave to appeal. CS can draft the SLP petition but the filing must be through an Advocate-on-Record (AOR) of the Supreme Court.
How should grounds of appeal be drafted for NCLAT?
Each ground should: (1) IDENTIFY the specific error in the NCLT order — 'The NCLT erred in holding that...' (2) EXPLAIN why it is wrong — citing the relevant legal provision or evidence, (3) STATE the correct position — what the NCLT should have held, (4) CITE supporting precedent (if available). Include: (a) LEGAL errors — wrong interpretation of Companies Act/IBC provisions, (b) FACTUAL errors — ignoring material evidence, wrong findings, (c) PROCEDURAL errors — violation of natural justice, wrong procedure, (d) JURISDICTIONAL errors — NCLT exceeded/failed to exercise jurisdiction. Include an OMNIBUS ground: 'The order is against law and the weight of evidence.'

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