Interlocutory Order Doctrine: attachment and sealing under Section 146 is an order of moment, not merely procedural.

An order under Section 146 directing attachment and sealing of immovable property is not confined to a purely interim or temporary step. An order that substantially affects the parties' rights, decides an important aspect of the dispute, or operates as an order of moment is not interlocutory. Applied to attachment and sealing of a flat under Sections 145 and 146, the order materially affects the controversy and is capable of judicial scrutiny as an intermediate order, rather than being excluded as merely procedural.

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Issues: Whether an order under Section 146 directing attachment and sealing of immovable property is an interlocutory order, and whether such an order can be treated as merely procedural so as to exclude revisional or inherent jurisdiction.

Analysis: The concept of interlocutory order was held to be confined to orders that are purely interim or temporary and that operate only as steps in aid of the proceeding. An order which substantially affects the rights of the parties, decides an important aspect of the proceeding, or otherwise amounts to an order of moment cannot be treated as interlocutory. Applying these principles to an order under Section 146 directing attachment and sealing of a flat, the Court reasoned that such an order is not a mere procedural step, but one that directly affects the rights of the parties and materially impacts an important aspect of the dispute under Sections 145 and 146.

Conclusion: An order under Section 146 directing attachment and sealing of property is not an interlocutory order and falls within the category of an intermediate or order of moment capable of judicial scrutiny.

Ratio Decidendi: An order is not interlocutory if it substantially affects the rights of the parties or an important aspect of the proceeding, even though the main proceeding remains pending.

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