Section 22 SICA protection does not cover post-scheme trade liabilities arising from goods supplied after sanction.

Section 22 of the Sick Industrial Companies (Special Provisions) Act, 1985 protects the implementation of a sanctioned rehabilitation scheme and bars enforcement only of liabilities reckoned in or covered by that scheme. Where the liability arises from transactions entered into after sanction, it falls outside the scheme and is not shielded by the statutory embargo. On that reasoning, post-scheme purchases of goods create an ordinary enforceable payment obligation, and the sick company cannot rely on section 22 to avoid payment for goods received after sanction.

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Issues: Whether the bar under section 22 of the Sick Industrial Companies (Special Provisions) Act, 1985 applies to a liability arising from goods supplied after the sanction of the scheme.

Analysis: Section 22 is intended to protect the implementation of a sanctioned scheme and to prevent interference with liabilities that are reckoned in, or covered by, the scheme. Where the liability arises from transactions entered into after the sanction of the scheme, such liability is not included in the scheme and is outside the protective umbrella of section 22. The post-scheme purchase of goods creates an ordinary enforceable obligation to pay, and it would be unreasonable to permit the sick company to receive goods after sanction without paying for them.

Conclusion: The bar under section 22 did not apply, and the plaintiff was entitled to decree.

Ratio Decidendi: The embargo under section 22 of the Sick Industrial Companies (Special Provisions) Act, 1985 extends only to liabilities reckoned in or covered by the sanctioned scheme, not to liabilities arising from post-scheme transactions.

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