The Mumbai bench of the National Company Law Tribunal (NCLT) admitted an insolvency petition filed by One97 Communications Ltd (Paytm) against Fabzen Technologies Pvt Ltd on June 18, 2025, initiating the Corporate Insolvency Resolution Process (CIRP) over unpaid digital advertising dues exceeding ₹3.41 crore.
Fabzen Technologies — the gaming company behind popular titles Ludo Empire, Callbreak Empire and Skill Patti Empire — now faces full insolvency proceedings under the Insolvency and Bankruptcy Code, according to Bar & Bench.
Background: How We Got Here
The dispute traces back to October 2024, when Fabzen Technologies allegedly began defaulting on invoices raised by Paytm for in-app advertising campaigns, despite a 60-day credit period and multiple follow-up attempts by Paytm, as reported by Bar & Bench.
The case is formally captioned One97 Communication Ltd v. Fabzen Technologies Pvt Ltd. Paytm filed the petition under the Insolvency and Bankruptcy Code (IBC) before the NCLT Mumbai bench.
- Fabzen’s default was established by the tribunal as crystallising from January 7, 2025, per Bar & Bench.
- Emails placed on record showed Fabzen repeatedly acknowledging outstanding dues and proposing a 12-month payment schedule while seeking more time to pay.
- Fabzen countered by claiming disputes over Paytm Ads campaign performance, citing emails from November 2024 and January 2025 about poor-quality user acquisition, high costs and missed campaign targets.
Fabzen additionally invoked the Promotion and Regulation of Online Gaming Act, 2025, arguing that new legal restrictions under that statute had wiped out the commercial basis of the advertising agreement.
The Ruling — Key Findings
The NCLT Mumbai bench passed its order on June 18, 2025, admitting the petition and formally initiating CIRP against Fabzen Technologies, according to Bar & Bench.
The tribunal squarely rejected Fabzen’s reliance on the Online Gaming Regulation Act, observing: “The operational debt claimed in the present petition had already become due and crystallised prior to the enactment of the said legislation.”
The bench noted that Fabzen’s default dated from January 7, 2025, while the Promotion and Regulation of Online Gaming Act, 2025 was passed only in August 2025 and operates prospectively — meaning it could not extinguish a debt that had already accrued.
The tribunal also declined to treat Fabzen’s performance-related email complaints as a genuine pre-existing dispute capable of defeating the IBC petition, given that Fabzen’s own correspondence had repeatedly acknowledged the outstanding dues and sought instalment arrangements.
The NCLT appointed Manish Lalji Dawda as the interim resolution professional (IRP) to oversee the CIRP. Dawda is a registered insolvency professional with the Insolvency and Bankruptcy Board of India, bearing registration number IBBI/IPA-001/IP-P-02506/2021-2022/13797, per IBBI records.
Reactions & What’s Next
Paytm was represented before the NCLT by Advocates Nikita Abhyankar, S. Vatsa and Vijayant, briefed by Gravitas Legal. Fabzen Technologies was represented by Advocates Devashish Godbole and Aman Pawar, as reported by Bar & Bench.
With CIRP now admitted, the interim resolution professional Manish Lalji Dawda takes control of the insolvency process. Creditors of Fabzen Technologies are expected to file their claims before the IRP in accordance with IBC timelines.
This development forms part of a broader pattern of Paytm using IBC proceedings to recover unpaid digital advertising dues from online gaming companies. In a comparable matter, an NCLT bench issued an insolvency notice against WinZO Games in November 2024 over ₹3.6 crore in unpaid advertising dues, as reported by MediaNama.
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What is the amount of debt claimed by Paytm against Fabzen Technologies in the NCLT insolvency petition?
Paytm’s One97 Communications Ltd claimed unpaid digital advertising dues exceeding ₹3.41 crore from Fabzen Technologies Pvt Ltd. The tribunal established the default date as January 7, 2025, according to Bar & Bench.
Who is the interim resolution professional appointed in the Fabzen Technologies CIRP?
The NCLT Mumbai bench appointed Manish Lalji Dawda as the interim resolution professional. He is registered with the IBBI under registration number IBBI/IPA-001/IP-P-02506/2021-2022/13797, per IBBI records.
Why did NCLT reject Fabzen’s defence based on the Online Gaming Regulation Act, 2025?
The tribunal held that Fabzen’s debt had already crystallised before the Act was enacted. Since the Promotion and Regulation of Online Gaming Act, 2025 was passed in August 2025 and operates prospectively, it could not extinguish a debt that arose from January 7, 2025, as reported by Bar & Bench.
What games does Fabzen Technologies operate?
Fabzen Technologies Pvt Ltd operates online skill gaming titles including Ludo Empire, Callbreak Empire and Skill Patti Empire, according to Bar & Bench.
Disclaimer
Disclaimer: This article is for general information only and does not constitute legal advice. Laws may change or vary by case — consult a qualified lawyer before acting. The Courtroom is not liable for any reliance on this content.
