On 21 May 2021 a two-judge bench of the Supreme Court, in Lalit Kumar Jain v. Union of India, upheld the Central Government's MCA Notification of 15 November 2019 selectively bringing Part III of the Insolvency and Bankruptcy Code into force for personal guarantors of corporate debtors as valid conditional legislation, and held that approval of a resolution plan for a corporate debtor under Section 31 does not, of itself, discharge a personal guarantor — surety liability rests on the independent footing of Section 128 of the Contract Act. A close reading of the judgment authored by Justice Ravindra Bhat, the doctrinal architecture of the Section 60(2) common-forum design, and the doctrinal arc through Dilip B. Jiwrajka.