Appeal under the DRT Act is not maintainable against purely procedural orders that do not affect substantive rights.

An appeal under section 20(1) of the Recovery of Debts Due to Banks and Financial Institutions Act, 1993 lies only against an order of the DRT that formally adjudicates upon and affects the parties' rights or liabilities. Purely procedural or interlocutory orders that merely regulate the conduct of proceedings do not determine substantive rights and are not appealable. The Act's objective of expeditious recovery would be undermined if appeals were entertained at every procedural stage. A purely procedural order was therefore treated as not appealable under section 20(1), and the appeal before the Appellate Tribunal was not maintainable.

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Issues: Whether an appeal under section 20(1) of the Recovery of Debts Due to Banks and Financial Institutions Act, 1993 lies against a purely procedural order of the Debts Recovery Tribunal that does not affect the rights or liabilities of the parties.

Analysis: The appellate remedy under section 20(1) is not intended to cover every order made by the Debts Recovery Tribunal. On the scheme of the Act, the jurisdiction of appeal is attracted only where the order formally adjudicates upon and affects the rights of the parties. Purely procedural or interlocutory orders, which merely regulate the conduct of proceedings and do not determine substantive rights or liabilities, are not appealable. The object of the Act is expeditious adjudication and recovery, and that object would be defeated if appeals were permitted at every procedural stage.

Conclusion: A purely procedural order that does not affect substantive rights is not appealable under section 20(1); the appeal before the Appellate Tribunal was therefore not maintainable.

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