By Richard Epling (September 7, 2017, 4:14 PM EDT) -- Section 524(e) of the Bankruptcy Code and its predecessor, Section 16 of the Bankruptcy Act of 1898, both unequivocally provide that only a debtor can obtain a discharge of indebtedness. With one limited exception in Section 524(g) of the Bankruptcy Code, both it and the act before it do not permit a bankruptcy court to grant a discharge to a nonpetitioner. However, many bankruptcy debtors propose broad releases of third-party nondebtors that control, lend to, insure or otherwise have significant relationships with the debtor and its estate. These releases are usually supported by an anti-suit injunction and can be nearly identical in scope to the bankruptcy discharge granted to the debtor. Beginning in the Depression era, debtors have found it expedient to grant forms of third-party releases to facilitate confirmation of Chapter 11 (and XI) plans....