Doctrine of merger prevents revival of an earlier Customs House Agent licence order after a later High Court order covered the same matter.

A prior adjudicatory direction cannot be separately revived or enforced once a subsequent High Court order has dealt with the same subject matter, because the earlier order merges into the later one. Here, the request to compel implementation of the Tribunal's earlier renewal direction failed since the High Court had later granted only liberty to apply for a temporary Customs House Agent licence without deciding the merits. The temporary licence application was also rejected on merits for non-fulfilment of regulatory conditions, and the affirming appellate order was left undisturbed. The challenge to revive the earlier direction was therefore not entertained.

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Issues: Whether the earlier Tribunal order directing renewal of the Customs House Agent licence could still be enforced after the subsequent High Court order, and whether the impugned rejection of the temporary licence application was liable to be interfered with.

Analysis: The High Court held that its earlier order in the connected writ petition had been passed without going into the merits and had granted only liberty to apply for a temporary Customs House Agent licence. In that situation, the earlier Tribunal order stood merged with the High Court's subsequent order and could no longer be independently revived or enforced. The Court also noted that the application for temporary licence had been rejected on merits for non-fulfilment of the regulatory conditions, and the appellate order affirming that rejection did not warrant interference in the present proceedings.

Conclusion: The request to revive and enforce the Tribunal's earlier renewal order was rejected, and the writ petition failed.

Final Conclusion: The challenge was not entertained on the ground that the earlier Tribunal direction had merged with the High Court's later order, leaving no basis to compel implementation of that earlier direction.

Ratio Decidendi: Once a subsequent court order covers the same matter, the earlier adjudicatory order merges into it and cannot be separately enforced or revived in collateral proceedings.

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