Interlocutory share valuation in oppression proceedings upheld where pleadings supported buy-out consideration and no prejudice was shown.

An interlocutory direction to appoint a valuer for shares in oppression and mismanagement proceedings was upheld because valuation is an expert exercise within the Tribunal's supervisory power and does not by itself determine rights or liabilities. The Tribunal relied on the parties' pleadings and correspondence showing willingness to consider a buy-out and valuation of the minority shareholding, and treated the recorded statements as part of the judicial record. As the order did not prejudice the appellant merely by requiring a report for further consideration, no appellate interference was warranted and the appeal failed.

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Issues: Whether the order appointing a valuer and directing valuation of the company's shares at the interlocutory stage was liable to be interfered with in appeal.

Analysis: The appeal arose from an interim order made in proceedings under Sections 241 and 242 of the Companies Act, 2013, where the parties' pleadings and correspondence showed an admitted willingness to consider a buy-out and valuation of the minority shareholding. The Tribunal noted that valuation is an expert exercise, that the role of the adjudicatory forum is supervisory, and that a valuation direction did not itself determine rights or liabilities. It also treated the statements recorded in the impugned order as conclusive judicial record, and found no basis to hold that the appellant suffered prejudice merely because a report was to be submitted for further consideration. In this setting, the direction to appoint a valuer was regarded as within the Tribunal's power and not premature or illegal.

Conclusion: The interim valuation order was upheld and the challenge to it failed.

Final Conclusion: The appeal was dismissed as the impugned order was held not to affect the appellant's legal rights or liabilities and no ground for appellate interference was made out.

Ratio Decidendi: An interlocutory direction for valuation of shares in proceedings for oppression and mismanagement is not interferable in appeal where it is supported by the pleadings or admissions of the parties and does not by itself prejudice or finally determine the parties' rights.

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