Bridging Jurisdictions: Cross-Border Insolvency in The Gift City Paradigm

14 November 2025

This article examines the critical need for harmonizing the Indian Insolvency and Bankruptcy
Code, 2016 (IBC), with the UNCITRAL Model Law on Cross-Border Insolvency in the context of
GIFT City (India’s International Financial Services Centre). While the IBC has strengthened India’s
domestic insolvency architecture, its cross-border insolvency framework remains underdeveloped.
Entities operating in GIFT City will inevitably interact with foreign creditors, own assets abroad,
and face multijurisdictional claims. Against this backdrop, the article analyses lacunae in India’s
present cross-border insolvency regime, reviews comparative jurisdictions, and proposes to
incorporate the Part Z as suggested by the Insolvency Law Committee. Below is the article titled “Bridging Jurisdictions: Cross- Border Insolvency in the Gift City Paradigm,” authored by our Managing Partner, Mr. Sameer Rastogi, and published in the ICSI Journal for the month of November, 2025.

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Bridging Jurisdictions: Cross-Border Insolvency in The Gift City Paradigm

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