For years, corporate insolvency in India was treated as a largely commercial exercise. Once a matter entered the Insolvency and Bankruptcy Code, 2016 (“ Code ”) framework, businesses assumed that risks were limited to financial outcomes i.e. haircuts, loss of control, or liquidation. That assumption is now proving to be dangerously outdated. A recent enforcement action by the Directorate of Enforcement (“ ED ”) in the matter of Richa Industries Limited (“ RIL ”) arising out o