Statutory locus for proof-of-debt appeals is limited to the affected creditor; rival creditors cannot invoke the appeal right.

Rule 164 of the Companies (Court) Rules, 1959 gives a right of appeal only to a creditor dissatisfied with the liquidator's decision on that creditor's own proof of debt. Read with Rule 165, the scheme does not permit a rival creditor to challenge the admission of another creditor's claim merely because it disputes the result. The right of appeal is statutory and cannot be assumed by a third party without express authority. On that basis, rival creditors lacked statutory locus to maintain appeals against the Official Liquidator's acceptance of workmen's proof of debt.

---

---

Issues: Whether appeals under Rule 164 of the Companies (Court) Rules, 1959 were maintainable at the instance of rival creditors challenging the Official Liquidator's admission of workmen's proof of debt.

Analysis: Rule 164 confers a right of appeal only on a creditor who is dissatisfied with the decision of the liquidator in respect of his own proof. Read with Rule 165, the scheme of the Companies (Court) Rules, 1959 shows that a rival creditor is not an appellant in such proceedings, but may seek leave to intervene if the workmen themselves challenge the determination. The right of appeal is not inherent and must be created by statute; therefore, a third-party creditor cannot invoke Rule 164 merely because it disputes the admission of another creditor's claim. The appellants, being creditors in their own right and not the persons whose proof had been accepted, had no statutory locus to maintain these appeals.

Conclusion: The appeals under Rule 164 were not maintainable at the instance of the appellants and were liable to be dismissed.

Ratio Decidendi: Under Rule 164 of the Companies (Court) Rules, 1959, the right of appeal against the liquidator's decision on proof of debt lies only to the creditor whose own claim is accepted or rejected, and not to a rival third-party creditor.

---