Inherent powers cannot grant relief beyond pleadings when entitlement to disputed property has not been adjudicated.

Inherent powers of a Company Court under the Companies (Court) Rules, 1959 cannot be used to grant relief beyond the pleadings. Rule 9 preserves only powers necessary to secure justice or prevent abuse of process, analogous to section 151 CPC, but not to award a substantive remedy that was neither specifically sought nor adjudicated. Here, the application was confined to the shed and related defaulted amount, while assignment of a separate land parcel and execution of a sale deed were not pleaded and the entitlement to that land was disputed. The direction to assign the land and execute the sale deed was therefore unsustainable and was set aside.

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Issues: Whether the Company Court could, in exercise of its inherent powers under the Companies (Court) Rules, direct assignment of a separate parcel of land and execution of a sale deed when no such specific relief was sought in the application.

Analysis: Rule 6 of the Companies (Court) Rules, 1959 makes the practice and procedure of the civil court applicable to company proceedings, and Rule 9 preserves only such inherent powers as are necessary for the ends of justice or to prevent abuse of process. Those powers are analogous to section 151 of the Code of Civil Procedure, 1908, but they do not permit grant of relief wholly outside the pleadings. The application before the Company Court was confined to the shed and the defaulted amount relating to that allotment. The request for assignment of the separate land parcel was neither specifically pleaded nor made the subject of a claim, and the entitlement to that land was itself disputed. In such circumstances, the relief could not be moulded to include a distinct property dispute not raised by the applicant.

Conclusion: The direction to assign the land and execute the sale deed was unsustainable and was set aside; the appeal succeeded.

Final Conclusion: The Company Court's equitable powers could not be used to grant a substantive relief outside the scope of the application and pleadings, especially where entitlement to the property remained in dispute.

Ratio Decidendi: Inherent powers of a company court cannot be invoked to grant a substantive relief not specifically sought in the pleadings, particularly where the disputed entitlement to the property has not been adjudicated on the merits.

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