Reasoned adjudication required for distinct interlocutory relief; impleadment refusal of subsequent purchasers was left undisturbed.

A distinct application seeking modification of an interim injunction could not be disposed of without independent reasons; the tribunal had not separately examined the requested alteration of the interim arrangement, so that order was set aside and remitted for fresh consideration by a reasoned order. In contrast, the refusal to implead subsequent purchasers was sustained because the order did not finally adjudicate their rights on merits, and no ground for interference was shown. The text notes that a separate substantive grievance requires a reasoned adjudication, while non-final orders may not justify appellate interference.

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Issues: (i) whether the order disposing of I.A. No. 352/2017, which sought modification of the interim injunction, could be sustained when no independent reason was assigned; (ii) whether interference was warranted with the order disposing of I.A. No. 222/2017, which sought impleadment of subsequent purchasers.

Issue (i): whether the order disposing of I.A. No. 352/2017, which sought modification of the interim injunction, could be sustained when no independent reason was assigned.

Analysis: The relief sought in I.A. No. 352/2017 was distinct from the relief sought in I.A. No. 222/2017. The tribunal disposed of the modification application without recording reasons and without independently examining the prayer for alteration of the interim arrangement. A separate application raising a different substantive grievance required a reasoned adjudication.

Conclusion: The order was set aside insofar as I.A. No. 352/2017 was concerned, and the matter was remitted for fresh consideration by a reasoned order.

Issue (ii): whether interference was warranted with the order disposing of I.A. No. 222/2017, which sought impleadment of subsequent purchasers.

Analysis: The tribunal rejected impleadment of subsequent purchasers, while leaving open the question of the applicability of lis pendens. The order did not finally determine the rights of the proposed parties on merits, and no ground for interference was made out in respect of that application.

Conclusion: The order was sustained insofar as I.A. No. 222/2017 was concerned.

Final Conclusion: The challenge succeeded only in part, with one application remanded for fresh decision and the other left undisturbed.

Ratio Decidendi: A distinct substantive application cannot be disposed of without independent reasons, and where an order does not finally adjudicate the rights raised, interference may be declined.

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