Jurisdiction of permanent bench and company winding-up matters must stay within the statutory framework and authorised seat.

The statutory scheme for the permanent Bench at Ranchi confined that Bench to cases arising from specified districts and did not authorise transfer of matters from the principal seat to Ranchi. The same framework also required winding-up and connected company proceedings to remain under a unified company jurisdiction before the authorised Company Judge at the principal seat, rather than being split between different judges or seats. The court treated the attempted allocation to the Ranchi Bench as unsustainable under the company-law framework, while noting that no further operative direction was issued because of impending reorganisation.

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Issues: (i) Whether proceedings instituted at the principal seat of the High Court could be transferred to the Ranchi Bench under the governing statute and rules. (ii) Whether winding-up proceedings and connected company matters could be allocated between different Company Judges within the same High Court, or whether such matters had to remain before the principal seat.

Issue (i): Whether proceedings instituted at the principal seat of the High Court could be transferred to the Ranchi Bench under the governing statute and rules.

Analysis: The statutory scheme establishing the permanent Bench at Ranchi confined its jurisdiction to cases arising from the specified districts, while reserving to the Chief Justice a discretion to direct that cases from those districts be heard at Patna. The rules were consistent with that scheme. On that reading, the power of transfer operated from Ranchi to Patna in appropriate cases, but did not authorise transfer of matters belonging to the principal seat to the Ranchi Bench.

Conclusion: The transfer of a case from the principal seat to the Ranchi Bench was impermissible and contrary to the governing Act and Rules.

Issue (ii): Whether winding-up proceedings and connected company matters could be allocated between different Company Judges within the same High Court, or whether such matters had to remain before the principal seat.

Analysis: Winding-up jurisdiction is part of the High Court's original company jurisdiction and is to be exercised through the Company Judge with the official liquidator attached to the High Court. The statutory scheme under the Companies Act and the company rules required a coherent and exclusive arrangement for liquidation proceedings, and the creditor-recovery regime also had to respect the pari passu principle under the company law framework. The Court held that such matters could not be split so as to create competing winding-up proceedings within the same High Court away from the principal seat. In the circumstances, the existing company proceeding at Ranchi was treated as one that should lie before the principal seat, though no separate direction was issued because the legal situation was about to change with the impending reorganisation.

Conclusion: Winding-up and connected company proceedings were to be dealt with by the Company Judge at the principal seat, and the attempted allocation to the Ranchi Bench was not sustainable.

Final Conclusion: The appeal succeeded, the transfer order was set aside, and the Court declared the governing jurisdictional position while leaving no further operative direction in view of the impending statutory reorganisation.

Ratio Decidendi: A case falling within the principal seat's jurisdiction cannot be transferred to a permanent bench unless the governing statute or rules expressly permit it, and winding-up jurisdiction must remain unified before the authorised Company Judge in accordance with the company-law scheme.

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