Given the task definition and input, reply with output. In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision. Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

Temex Energy, Inc. v. Haste & Kirschner (In re Amarex, Inc.), 96 B.R. 330, 332 (Bankr.W.D.Okla.1989) (citing In re Stratford of Tex., Inc.). To be sure, "(a) Chapter 11 Plan, whether it is one contemplating reorganization or the liquidation of assets, is nothing more nor less than a contract between a debtor and the creditors of the bankruptcy estate." Retail Marketing Co. v. Northwest Nat'l Bank (In re Mako, Inc.), 120 B.R. 203, 207 (Bankr.E.D.Okla.1990), on subsequent remand on other grounds, 127 B.R. 474, 476 (1991). That the Plan was later confirmed by court or der changes not the validity of the contract. See In re Stratford of Tex., Inc., 635 F.2d at 368; see also United States v. ITT Continental Baking Co., 420 U.S. 223, 236-37, 95 S.Ct. 926, 934, 43 L.Ed.2d 148 (1975) (<HOLDING>). Consequently, for purposes of this ruling,
Holding statements: (A) holding that coas should be construed liberally (B) holding that consent decrees and orders should be construed as contracts (C) holding that railroad immunity act should be strictly construed (D) holding that a governments consent to be sued must be construed strictly in favor of the sovereign (E) holding that ambiguities in insurance contracts should be favorably construed to the insured
holding that coas should be construed liberally