Inherent powers under Rule 11 do not permit review or recall by reappraising evidence and altering factual findings.

Rule 11 of the NCLAT Rules, 2016 confers only inherent power to pass orders necessary to secure justice or prevent abuse of process, and it does not create a general power of review. The Tribunal noted that Section 420 of the Companies Act, 2013 is confined to rectification of mistakes apparent from the record and cannot be used to reappraise evidence or substitute a fresh factual finding. Even if the earlier observation on the alleged guarantee was wrong, correction would require reopening the merits, which lay beyond Rule 11. The review application was therefore not maintainable.

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Issues: Whether the Appellate Tribunal could invoke Rule 11 of the NCLAT Rules, 2016 to review or recall its earlier judgment by reappraising the record and substituting its finding on the alleged guarantee issued by the corporate debtor.

Analysis: Rule 11 confers only inherent powers to make orders necessary to meet the ends of justice or prevent abuse of process. Those powers do not include a general power of review. The Tribunal held that Section 420 of the Companies Act, 2013 applies to rectification of mistakes apparent from the record by the Tribunal, and does not enlarge the appellate tribunal's jurisdiction to re-examine evidence or sit in appeal over its own findings. Even if the earlier observation on the guarantee were erroneous, correcting it would require reappraisal of material and substitution of a factual finding, which lies beyond the limited scope of Rule 11.

Conclusion: Rule 11 could not be invoked to reopen the merits or alter the earlier finding, and the review application was not maintainable.

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