Appeal rights in winding-up proceedings extend to final orders under company law, not to merely interlocutory or ministerial orders.

Section 202 of the Companies Act was construed broadly to allow an appeal from orders made in company winding-up proceedings, notwithstanding restrictions under the Civil Procedure Code. The appellate right applies only where the order is final in substance, determines a dispute, or deprives a party of a substantial and important right; it does not extend to mere formal, ministerial, or interlocutory orders. Earlier narrower authorities were distinguished because they concerned orders governed directly by the Civil Procedure Code rather than the wider question under section 202.

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Issues: Whether an appeal lies under section 202 of the Companies Act from an order made in liquidation proceedings by the District Judge, notwithstanding the restrictions on appeals under the Civil Procedure Code.

Analysis: Section 202 was construed broadly to cover orders made in the matter of winding up of a company, but the appellate right was held not to extend to mere formal, ministerial, or interlocutory orders. The provision was read as permitting an appeal where the order finally decides a dispute between the parties or deprives a party of a substantial and important right. Earlier decisions relied on for a narrower construction were distinguished on their facts, since they involved orders governed directly by the Civil Procedure Code and no broader question under section 202 arose.

Conclusion: An appeal does lie under section 202 of the Companies Act against such an order, provided it is final in substance and not merely interlocutory or formal.

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