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In chapter 12 and chapter 13 cases, the debtor is usually entitled to a discharge upon completion of all payments under the plan. The court may grant a "hardship discharge" to a chapter 12 debtor even though the debtor has failed to complete plan payments.The Chapter 13 debtor may receive a discharge upon completion of all bankruptcy plan payments under 11 USC 1328(a). Completing a simple Attestation Form may lead to an agreement to settle the debtor's undue hardship discharge proceeding. "); Charissa Potts,. For most exceptions to discharge, the creditor must request a court order. Objection. The court may grant a "hardship discharge" to a chapter 12 debtor even though the debtor has failed to complete plan payments. The court will issue the debtor a discharge once all due payments have been completed, and the matter will be closed. The court will issue the debtor a discharge once all due payments have been completed, and the matter will be closed. Delinquent Debt Collection.