Inherent power cannot be used to recall final insolvency orders absent express statutory authority.

The NCLT held that it had no jurisdiction to review, recall, or quash its final admission and resolution-plan approval orders once they had attained finality. It found that neither section 60(5) of the Insolvency and Bankruptcy Code nor Rule 11 of the NCLT Rules confers an inherent power to reopen such concluded proceedings, and that review is available only where expressly provided by statute. The application was therefore beyond jurisdiction, not maintainable, and rejected.

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Issues: Whether the Tribunal had jurisdiction to recall or quash its earlier order and whether the application seeking such relief was maintainable.

Analysis: The application sought to unsettle the earlier admission order and subsequent approval of the resolution plan, but those orders had attained finality. The Tribunal held that it was not vested with power to review or recall its own order under section 60(5) of the Insolvency and Bankruptcy Code, 2016 or under Rule 11 of the National Company Law Tribunal Rules, 2016. The reasoning also emphasised that review is a creature of statute and cannot be exercised as an appellate power. In these circumstances, the challenge to the earlier proceedings was treated as beyond jurisdiction and contrary to law.

Conclusion: The application was not maintainable and was rejected.

Ratio Decidendi: A tribunal cannot invoke inherent powers to review or recall its own final order in the absence of an express statutory power of review or recall.

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