Recalling a procedural closure order is distinct from reviewing merits, and inherent powers may permit recall of a reply filing restriction.

An adjudicatory body cannot review a substantive decision on merits, but it may recall a procedural order closing a party's right to file a reply. The distinction turned on whether any issue had already been finally adjudicated; where no substantive matter was decided and only the question of taking the reply on record remained, the inherent power under Rule 11 of the NCLT Rules, 2016 could be invoked. The Adjudicating Authority was therefore held to have jurisdiction to recall the closure order, and the matter was remitted for consideration of the recall application on merits.

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Issues: Whether the Adjudicating Authority has jurisdiction to recall an order closing the right to file reply, as distinct from impermissible review on merits.

Analysis: The distinction between recalling an order and reviewing a decision on merits was central to the determination. An adjudicatory body lacks power to review a substantive determination already made on merits, but the closure of a party's right to file a reply is a procedural order. In relation to such procedural matters, the inherent power under Rule 11 of the National Company Law Tribunal Rules, 2016 can be invoked to recall the order where no substantial issue has been adjudicated and the question is only whether the reply should be taken on record.

Conclusion: The Adjudicating Authority had jurisdiction to recall the order closing the right to file reply. The appeal was therefore allowed and the matter was sent back for consideration of the recall application on merits.

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