In P. Mohanraj v Shah Brothers Ispat Pvt Ltd (2021), the Supreme Court held that proceedings under…

P. Mohanraj (2021) held that "a Section 138/141 proceeding against a corporate debtor is covered by Section 14(1)(a) of the IBC". The moratorium applies only to the corporate debtor, so the directors and other natural persons named in section 141 continue to be liable under the Negotiable Instruments Act. The quasi-criminal nature of the proceeding did not take it outside section 14.