Post-winding-up property transfers are void unless validated, and sale deeds without prior title cannot override liquidation rights.

Post-winding-up sale deeds executed in favour of the appellant were treated as void under Section 536(2) of the Companies Act, 1956 because the transfers were made after commencement of winding up and the appellant failed to produce any antecedent document showing prior enforceable title. The record instead supported the company's claim over the lands through parent documents, powers of attorney, consideration receipts and custody of original title papers. In these circumstances, the court found no basis to validate the transfers, so the application was dismissed and the challenged land transactions could not defeat the liquidation process.

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Issues: Whether the sale deeds executed in favour of the appellant after commencement of winding up were void under Section 536(2) of the Companies Act, 1956, and whether the transaction was liable to be validated.

Analysis: Section 536(2) renders any disposition of the property of a company made after the commencement of winding up void unless the Court otherwise orders. The materials showed that the appellant's title was traced to sale deeds executed in 2019 onwards, and no antecedent document prior to commencement of winding up was produced. The record also supported the company's claim over the lands through parent documents, powers of attorney, consideration receipts, and custody of original title papers. In these circumstances, the post-winding-up transfers could not be treated as valid dispositions.

Conclusion: The sale deeds were void under Section 536(2) and no ground was made out to validate the transfers. The dismissal of the application was .

Final Conclusion: The appeal failed because the challenged land transfers, having been made after commencement of winding up, could not defeat the company liquidation process.

Ratio Decidendi: A disposition of a company's property made after the commencement of winding up is void unless the Court specifically orders otherwise, and a transfer based on post-winding-up sale deeds cannot be validated in the absence of a prior enforceable title.

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