Interlocutory Order Merger: appeal rendered infructuous after a comprehensive final order incorporated and superseded the interim relief.

Whether an appeal against an interim order became infructuous was examined by reference to a subsequent comprehensive common order that finally disposed of the company petition, appointed a Forensic Auditor to examine SPA compliance and disputed receivables, removed the Managing Director and appointed an Independent Administrator with supervisory authority, and continued the interim order under that oversight; the article concludes the interlocutory relief merged into the final supervisory framework and the appeal was dismissed as having become infructuous because no effective appellate relief remained.

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Issues: Whether the present appeal against the interim order dated 15.03.2023 has become infructuous/merged into the subsequent comprehensive common order dated 18.07.2025 passed by the Adjudicating Authority in CP No. 5 of 2023 and connected matters, thereby rendering appellate adjudication of the interim order unnecessary.

Analysis: The Tribunal examined the scope and operative directions of the common order dated 18.07.2025 which (i) finally disposed of CP No. 5 of 2023 and connected applications, (ii) appointed an Independent Forensic Auditor to examine compliance with the Share Purchase Agreement and disputed receivables, (iii) removed the Managing Director and appointed an Independent Administrator with authority to oversee operations, bank accounts and the forensic audit, and (iv) continued the interim order dated 15.03.2023 subject to oversight by the Independent Administrator. The Tribunal applied the principle that an interlocutory order may merge into a subsequent final adjudication by the superior forum when the later order creates a comprehensive supervisory framework that addresses and regulates the very matters which formed the substratum of the interlocutory grievance. Given that the common order subjects disputed receivables, representation in proceedings, bank operations and SPA compliance to forensic scrutiny and Tribunal/Administrator oversight, any effective relief that could be granted by this appeal against the standalone interim direction would no longer produce practical consequences.

Conclusion: The appeal is dismissed as having become infructuous because the common order dated 18.07.2025 finally disposed of the company petition and incorporated, regulated and superseded the interim order dated 15.03.2023; no effective appellate relief on the challenged interim direction remains available.

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