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 [Internet]. 2026 Jun. 30 [cited 2026 Jul. 2];19(S5):1189-98. Available from: https://journalofdaoiststudies.org/index.php/journal/article/view/986