Doctrine of merger barred Tribunal review after Supreme Court dismissal of the appeal, with only brief interim protection granted.

Once the Supreme Court dismissed the civil appeal, the doctrine of merger applied and the Tribunal's earlier final order merged in the Supreme Court's order. As a result, the Tribunal had no jurisdiction to review or modify that order, and any further challenge had to be taken to the Supreme Court. The applications were therefore rejected, although limited interim protection against coercive recovery was granted for four weeks.

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Issues: Whether the Tribunal could review or modify its earlier order after the civil appeal against that order had been dismissed by the Supreme Court, and whether the resulting merger barred further review before the Tribunal.

Analysis: The dismissal of the civil appeal by the Supreme Court attracted the doctrine of merger, because once appellate jurisdiction of the Supreme Court is invoked and the appeal is decided, the order of the lower forum merges in the Supreme Court's order. In such a situation, the Tribunal has no jurisdiction to entertain a review of its earlier final order. The proper course for the applicant, if so advised, is to approach the Supreme Court. The Tribunal nevertheless granted limited interim protection for four weeks against coercive recovery.

Conclusion: The Tribunal held that it lacked jurisdiction to review or modify its earlier order and rejected the applications, while granting limited temporary protection against coercive recovery for four weeks.

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