Limited recall jurisdiction under NCLT Rules cannot be used to review a merits order after participation in proceedings.

Rule 11 of the NCLT Rules preserves only a narrow inherent power to recall orders in limited situations such as jurisdictional defect, absence of notice, fraud, collusion, or an apparent procedural error. It does not confer a power of review or permit re-opening of a matter already decided on merits. Because the appellant had participated in the proceedings and the recall application sought to revisit the merits of the earlier order, the application was outside the scope of recall jurisdiction and was not maintainable. The rejection of the recall request was therefore justified and required no interference.

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Issues: Whether an application under Rule 11 of the NCLT Rules, 2016 could be entertained to recall an order passed on merits after participation in the proceedings, and whether the dismissal of such recall application called for interference.

Analysis: Rule 11 preserves only the inherent power of the Tribunal to make orders necessary to meet the ends of justice or prevent abuse of process. That power permits recall in limited situations such as jurisdictional defect, lack of notice, fraud, collusion, or a procedural error apparent on the record, but it does not confer a power of review or a power to re-open and re-adjudicate a matter already decided on merits. The impugned order of 24.03.2025 was passed after the appellant participated in the proceedings and the recall application sought to revisit the merits of that order under the guise of recall. Such a challenge was outside the narrow scope of recall jurisdiction.

Conclusion: The recall application was not maintainable as it amounted to a review of an order passed on merits, and the rejection of the recall application was /justified and not liable to be interfered with.

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