Doctrine of merger bars tribunal review once Supreme Court appeal is dismissed and the order has merged.

After dismissal of the civil appeals by the Supreme Court, the doctrine of merger applied and the Tribunal's final order ceased to exist independently for review or rectification purposes. Once appellate jurisdiction had been invoked and exercised by the Supreme Court, the Tribunal could not reopen the matter by entertaining a rectification or review application. The operative effect was that the application was not maintainable, and the Tribunal lacked jurisdiction to consider it at that stage.

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Issues: Whether the Tribunal had jurisdiction to entertain the rectification or review application after the final order had been carried in appeal to the Supreme Court and the appeal had been dismissed.

Analysis: The dismissal of the civil appeals by the Supreme Court attracted the doctrine of merger. Once appellate jurisdiction had been invoked and the Supreme Court had disposed of the appeals, the Tribunal's order ceased to exist independently for the purpose of a review or rectification at the Tribunal level. The controlling principle is that, after merger, the lower forum cannot reopen the matter by exercising review jurisdiction.

Conclusion: The rectification or review application was not maintainable and the Tribunal had no jurisdiction to entertain it.

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