Show cause notices in contempt are not appealable, while document production orders for forensic audits remain within tribunal power.

A mere show cause notice issued in contempt proceedings is not an appealable adjudication because it does not determine any right or contention; the alleged contemner must first respond before the Tribunal. Directions requiring production of documents and cooperation with a forensic auditor are sustainable when they fall within the Tribunal's statutory power to order discovery and production under the Companies Act, 2013, and when they are confined to relevant transactions. Where such a direction has already been superseded by a later order, there is no basis to keep the appeal pending or to interfere.

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Issues: (i) Whether an appeal lies against a show cause notice issued in contempt proceedings; (ii) Whether the direction requiring production of documents and cooperation with the forensic auditor called for interference.

Issue (i): Whether an appeal lies against a show cause notice issued in contempt proceedings.

Analysis: A mere notice initiating contempt proceedings does not finally decide any right or contention. Appealability arises only from an order that adjudicates a dispute affecting the rights of the alleged contemner. Since the impugned order was only a show cause notice, the appellant was left at liberty to respond before the Tribunal.

Conclusion: The appeal against the show cause notice was not entertained on merits and the appellant was permitted to file a reply before the Tribunal.

Issue (ii): Whether the direction requiring production of documents and cooperation with the forensic auditor called for interference.

Analysis: The Tribunal's power to require discovery and production of documents, and to secure cooperation for completion of a forensic audit, flows from Section 424(2)(b) of the Companies Act, 2013. The direction was confined to disclosures relating to transactions with the concerned company and had already been superseded by a later order. In these circumstances, no ground was found to keep the appeal pending or to interfere with the direction.

Conclusion: The challenge to the disclosure direction failed and the appeal was dismissed.

Final Conclusion: The connected matters were brought to an end by permitting a response before the Tribunal in one matter and declining interference in the other, with all pending applications also disposed of.

Ratio Decidendi: A mere show cause notice in contempt proceedings is not an appealable adjudication of rights, while directions for discovery, production of documents, and cooperation with a forensic auditor are sustainable where issued within the Tribunal's statutory powers.

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