In the case of Unique Metals Limited, all the creditors have been satisfied. Can the Adjudicating Authority without waiting for 180 days of Resolution Process, approve Resolution Plan under Section 31 of IBC ?

According to Section 12 of the Insolvency and Bankruptcy Code, 2016, the corporate insolvency resolution process shall be completed within a period of 180 days from the date of admission of the application to initiate such process. Section 31(1) of the Insolvency and Bankruptcy Code, 2016 mentions that if the Adjudicating Authority is satisfied that the resolution plan as approved by the committee of creditors under sub-section (4) of section 30 meets the requirements as referred to in sub-section (2) of section 30, it shall by order approve the resolution plan which shall be binding on the corporate debtor and its employees, members, creditors, including the Central Government, any State Government or any local authority to whom a debt in respect of the payment ofdues arising under any law for the time being in force, such as authorities to whom statutory dues are owed, guarantors and other stakeholders involved in the resolution plan. Provided that the Adjudicating Authority shall, before passing an order for approval of resolution plan under this sub-section, satisfy that the resolution plan has provisions for its effective implementation. Where all creditors have been satisfied, Adjudicating Authority, without waiting for 180 days of resolution process may approve resolution plan under Section 31 after recording its satisfaction that all creditors have been paid/ satisfied and any other creditor do not claim any amount in absence of default and required to close the Insolvency Resolution Process. If approval of the plan is granted, the moratorium order passed shall cease to have effect in view of sub- section (3) of Section 31. (Prowess International Pvt. Ltd. vs Parker Hannifin India Pvt. Ltd. 2017 140 CLA 217 NCLAT)