IBBI Cancels Registration of Valuer for Suppressing Criminal Proceedings in Application [Read Order]

The Insolvency and Bankruptcy Board ofIndia (IBBI) has cancelled the registration of a valuer for failing to disclose pending criminal proceedings at the time of seeking registration. Mr. Shreegopal Govindram Mundhra was registered as a valuer in the Land and Building asset class in January 2019. According to a recent disciplinary order dated 2nd June 2025, IBBI has revoked his registration after finding that he had suppressed material information about a chargesheet filed against him by the CBI prior to his registration.

A complaint had been filed with IBBI alleging that Mr. Mundhra, while applying for registration as a valuer in November 2018, failed to disclose that he had been chargesheeted in a criminal case pending before the CBI Special Court in Ahmedabad. The charges, dating back to 2013, relate to alleged offenses under multiple sections of the Indian Penal Code including cheating, forgery, and destruction of evidence, as well as offenses under the Prevention of Corruption Act.

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IBBI’s investigation revealed that Mr. Mundhra answered No to both questions in the application form that asked whether he had ever been convicted or had any pending criminal proceedings. Official records showed that a chargesheet had been filed against him in July 2013, and the case was still pending when he applied for registration, and remained pending even on the date his registration was granted.

The Board had contacted Mr. Mundhra by email in October and November 2024 seeking clarification, but he failed to respond initially. Later, he admitted that he had not disclosed the chargesheet, reasoning that the case was at trial stage and no formal charges had been framed. He also stated that he had filed a discharge application, and subsequently a criminal revision before the Bombay High Court, both of which did not result in relief. The High Court revision was eventually withdrawn.

In his defense, Mr. Mundhra claimed that the omission was based on his belief that disclosure was not required unless charges had been formally framed or a conviction had occurred. He also argued that the matter pertained to a dispute in valuation methodology and that there was no dishonest intent.

The IBBI rejected these explanations. The Board held that the onus to disclose any pending criminal matter, especially one involving serious offenses like conspiracy, cheating, and corruption, was squarely on the applicant.

In its order, IBBI asserted that valuers play a crucial role in insolvency proceedings under the IBC, where accurate valuations directly impact decision-making by creditors and courts the court relied on the Delhi High Court’s ruling in Cushman & Wakefield v. UOI, in which it was held that valuation is a domain requiring not just technical skill but a high degree of professional ethics and public trust.

The Board concluded that Mr. Mundhra had violated Rule 3(1)(k) and Rule 7 of the Companies (Registered Valuers and Valuation) Rules, 2017, along with Clauses 2 and 3 of the Model Code of Conduct, by misrepresenting facts in his registration form and failing to uphold integrity.

As a result, the IBBI cancelled the registration of Mr. Mundhra, and the cancellation was to come into effect 30 days from the date of the order. The show cause notice issued to him was to be formally disposed of.

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