Wednesday, November 5, 2025

AFFIDAVIT IN REPLY TO THE APPLICATION UNDER SECTION 66 OF IBC ON BEHALF OF RESPONDENT NO. 1, HIRAK NATH SOUNTH

 

BEFORE THE HON’BLE NATIONAL COMPANY LAW TRIBUNAL, KOLKATA BENCH

IA No. (IBC) 1339/KB/2025
in
CP (IB) No. 2137/KB/2019

IN THE MATTER OF:
Samskar Financial Services Private Limited … Financial Creditor

Versus
Roofers Infrastructure India Private Limited … Corporate Debtor

AND IN THE MATTER OF:
Tapan Chakraborty … Resolution Professional / Applicant

Versus

  1. Hirak Nath Sounth … Respondent No. 1
  2. Jayanti Sounth … Respondent No. 2

 

AFFIDAVIT IN REPLY TO THE APPLICATION UNDER SECTION 66 OF IBC ON BEHALF OF RESPONDENT NO. 1, HIRAK NATH  SOUNTH;

 

I, Smt. Hirak Nath Sounth, Son of Late Khudiram Sounth, aged about 49 years, by faith Hindu, by occupation unemployed, residing at Diamond Tower, Jhapetapur, Kharagpur, Midnapur West, Pin – 721301, presently suspended director of Roofers Infrastructure India Private Limited, holding DIN 01642164, do hereby solemnly affirm and state as follows;

 

(1)  I am the Respondent No. 1, in the above matter and being conversant with the facts of the case, am competent to swear this affidavit.

 

(2)  I deny and dispute all allegations, statements and averments made in the application filed by the Resolution Professional under Section 66 of the Insolvency and Bankruptcy Code, 2016 (IBC), save and except those specifically admitted herein.

 

(3)  The present application is not maintainable against me either in law or on facts.

 

(4)  The Corporate Debtor, Roofers Infrastructure India Pvt. Ltd., has been a non-active company since FY 2011–12, with no business activity, operations or transactions for more than a decade.

 

(5)  The company exists only on paper, has no registered or functional office, and does not own or possess any movable or immovable property.

 

(6)  I do not possess any books of account, statutory records, documents or information of the company. None are in my custody or control. Therefore, the allegation of non-cooperation or concealment is wholly false and misconceived.

 

(7)  The affairs of the Corporate Debtor, along with other associated companies, are under the supervision of the One-Man Committee headed by Hon’ble Justice S.P. Talukdar (Retd.), constituted on 01.02.2016. By order dated 14.09.2017 passed by the Hon’ble Calcutta High Court in W.P. No. 24057(W) of 2015, the said Committee took charge of the Corporate Debtor as well.

 

Photostat copy of the order dated 14.09.2017, passed by the Hon’ble High Court at Calcutta in W.P. No. 24057(W) of 2015, is annexed herewith and marked as Annexure – “A”.

 

(8)  Accordingly, all affairs of the Corporate Debtor are under judicial supervision. A winding up proceeding under Sections 271 and 272 of the Companies Act, 2013, being CP/306(KB)/2021, has been initiated by the Registrar of Companies, West Bengal, and is pending before Hon’ble NCLT Bench–II, Kolkata. The next date of hearing is fixed on 23.09.2025, in which IDBI Bank has entered appearance as an intervener.

 

Photostat copy of available daily orders are annexed herewith collectively and marked as Annexure – “B”.

 

(9)  The Central Bureau of Investigation, EO-IV, Kolkata, has registered FIR No. RC-9/E/17-EOIV-Kol., dated 25.05.2017 under Sections 120B, 420, 467, 468, 471 IPC against the Roofers Group of Companies, including the present Corporate Debtor.

 

Photostat copy of the said CBI FIR is annexed herewith and marked as Annexure – “C”.

 

(10)              The Corporate Debtor is also subject to multiple recovery and criminal cases, inter alia:

 

(i)   O.A. No. 415 of 2015 (IDBI Bank v. Roofers Infrastructure India Pvt. Ltd.) pending before DRT Kolkata–I, wherein a Recovery Certificate has been sought.

(ii)  CBI Case No. 08 of 2017 at the behest of IDBI Bank against the Corporate Debtor and others, pending before Ld. 22nd Judicial Magistrate, Bankshall Court, Kolkata.

 

Photostat copy of the Case Status are annexed herewith collectively, and marked as Annexure – “D”.

 

 

(11)              I say that the provision of Section 66 of the IBC requires intent to defraud creditors or wrongful trading. No such intent can be attributed to me. In fact, the Corporate Debtor has long been under judicial and investigative control, leaving no scope for fraudulent conduct on my part.

 

In view of the above facts and circumstances, I most respectfully pray that this Hon’ble Tribunal may be pleased to;

 

a)  Dismiss the present application filed against me under Section 66 of the IBC as misconceived, baseless, and not maintainable;

 

b)  Hold that I have duly complied with obligations of cooperation, and that no records, assets, or documents are in my possession;

 

c)  Take note that the Corporate Debtor is already under multiple judicial, investigative, and statutory proceedings including winding up before NCLT, CBI investigation, and recovery cases before DRT and criminal courts;

 

d)  Pass such other or further orders as this Hon’ble Tribunal may deem fit and proper.

 

And for this act of kindness, the Petitioner as in duty bound shall ever pray.

 

 

 

 

 

 

 

 

Verification

 

I, Hirak Nath Sounth, the deponent above named, do hereby verify that the contents of paragraphs 1 to 9 are true and correct to my knowledge and belief, and nothing material has been concealed.

Verified at Kolkata on this _______ day of November, 2025.

 

 

 

DEPONENT
Identified by me:

Advocate

Prepared in my chamber;


Advocate

Date: ______ November, 2025
Place: Kolkata

 

NOTARY

 

 

No comments:

Post a Comment