Extended limitation challenge treated as reviewable on documentary record; appeal admitted and interim stay of coercive action granted pending disposal.

Challenge to invocation of the extended limitation period was treated as a technical legal question susceptible to determination on undisputed documentary records; the court formed a prima facie view on that legal issue to justify entertaining the writ appeal. Because the challenge rested on documentary material, the appeal was admitted and interim protection granted: the respondent was directed to file an affidavit in opposition and no coercive action to enforce the original demand shall be taken until the statutory appeal is finally heard and disposed of.

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Issues: Whether the writ appeal challenging invocation of extended period of limitation in the adjudication order may be entertained and whether interim relief in the form of stay of coercive action should be granted pending disposal of the statutory appeal.

Analysis: The Court examined the record and found that the challenge to the original adjudication order on the ground of invocation of extended limitation is a technical issue capable of being adjudicated on the available and undisputed documentary record. The Court formed a prima facie view on that issue for the limited purpose of entertaining the appeal. Given the nature of the challenge and the undisputed factual material, the Court considered it appropriate to admit the appeal and direct the respondent to file an affidavit in opposition while affording interim protection to the appellants.

Conclusion: The appeal is entertained and interim relief is granted in favour of the appellants; the respondent is directed to file an affidavit in opposition and no coercive action shall be initiated to enforce the demand in the original order dated 31 January 2024 until the appeal is finally heard and disposed of.

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