Judicial interference with appellate tribunal judgment: impleadment challenge dismissed; NCLAT order quashed and NCLT order restored

Judicial interference with an appellate tribunal judgment is limited where no cogent reason for interference exists, resulting in dismissal of an appeal. Challenges to impleadment or intervention must meet requisite standards; absence of compelling grounds precludes appellate relief. An appellate order was quashed for disregarding an earlier order affirmed by higher authority, and the original tribunal order was restored as a consequence. The operative effect affirms application of precedent and appellate restraint, endorses quashing of administrative orders that contravene prior affirmed directions, and restores the decision of the lower tribunal.

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Issues: (i) Whether Civil Appeal No.258 of 2020 should be entertained and whether the impugned judgment warrants interference; (ii) Whether Civil Appeal No.2520 of 2020 should be allowed by quashing the NCLAT order that proceeded in ignorance of an earlier order and restoring the order of the National Company Law Tribunal.

Issue (i): Whether Civil Appeal No.258 of 2020 merits interference with the impugned judgment.

Analysis: The Court examined the record and submissions and considered whether there exists any cogent reason to intervene in the judgment under challenge. The Court found no basis to disturb the impugned judgment on the merits or on any jurisdictional ground.

Conclusion: The appeal is dismissed and the impugned judgment is affirmed.

Issue (ii): Whether the impugned NCLAT order in Civil Appeal No.2520 of 2020, which proceeded in ignorance of an earlier NCLAT order affirmed by this Court, should be quashed and the NCLT order restored.

Analysis: The Court noted that the impugned NCLAT order was made without regard to an earlier NCLAT order of 19th August, 2019 which this Court affirmed in Civil Appeal No.258 of 2020. In light of that affirmation, the subsequent NCLAT order is inconsistent with the earlier order affirmed by the Court and therefore susceptible to being set aside to restore the prior tribunal order.

Conclusion: The impugned NCLAT order is quashed and set aside and the order of the National Company Law Tribunal is restored; the appeal is allowed.

Final Conclusion: The Court dismissed one appeal for want of merit while allowing the connected appeal which relied on and conflicted with an earlier order affirmed by this Court, resulting in partial allowance of the overall proceedings.

Ratio Decidendi: Where an appellate order is rendered in ignorance of a prior order affirmed by this Court, the subsequent order may be quashed and the earlier tribunal order restored to maintain consistency and legal effect of the affirmed order.

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