Merger doctrine bars separate challenge to ex parte CHA licence suspension once a later hearing-based order continues the suspension

A challenge to an ex parte suspension order of a CHA licence was not entertained because a later order, passed after hearing the respondent, continued the suspension. The earlier order was treated as having merged into the subsequent order, so the legality of the ex parte order did not require separate adjudication. The existence of a separate challenge to the later order was also noted, and the appeal was disposed of without examining the initial suspension order on its own.

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Issues: Whether the appeal against the ex parte suspension order of the CHA licence survived after a subsequent order, passed after hearing the respondent, continued the suspension and the earlier order merged in the later order.

Analysis: The only substantive question was whether the challenge to the initial suspension order could be entertained when a subsequent order, passed after giving a hearing, had already continued the suspension. Since the earlier order had merged in the later order, the legality of the ex parte order no longer required independent adjudication. The existence of a separate challenge to the subsequent order was also noted.

Conclusion: The appeal was not entertained and was disposed of.

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