Quantified liability inclusive of interest bars further interest where the appellate order omits any additional interest direction.

The appellate order quantified the payable amount as inclusive of all interest, and that figure was treated as the final liability after accounting for admitted dues, payments already made, and interest. Because the order did not provide for any further interest on default, the omission was treated as a refusal of additional interest. The earlier trial court direction merged into the appellate order, so no separate or supplementary interest could be claimed by relying on the earlier order or by expanding the default clause. The payable amount remained confined to the sum fixed by the appellate court.

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Issues: Whether the appellate order, by quantifying the amount payable as inclusive of all interest and omitting any further direction for interest on default, left scope for the company court to award additional interest; and whether the trial court's earlier direction on interest survived after the appellate order.

Analysis: The quantified amount fixed by the appellate order was treated as the final amount payable, the figure having been arrived at after taking into account the admitted liability, the amount already paid, and the interest element. The appellate order expressly stated that the sum was inclusive of all interest and, while prescribing consequences of default, it did not provide for any further interest. In such a situation, the omission of a fresh interest direction was treated as a refusal of further interest. The earlier order of the trial court was held to have merged in the appellate order, leaving no scope to supplement the appellate directions by invoking the earlier order or by reading into the default clause an additional liability to pay interest.

Conclusion: No further interest could be awarded beyond the amount quantified by the appellate court, and the petitioner was entitled only to the sum fixed as inclusive of all interest.

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