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 2026, 19, 1189-1198.