Mahender Pal Arora, Dr. Vikalp Shrivastava, Dr. Avinash Kumar, “Creditor-Led CIRP under IBC has instilled fear in the Corporate Debtors of India, while bankruptcy under U.S. Bankruptcy Code is debtor-friendly and UK insolvency is known for speed, lower professional costs, creditor protection and reduced litigation”, jds, vol. 19, no. S5, pp. 1189–1198, Jun. 2026.