Article 227 supervision and contempt jurisdiction cannot be used to reopen merits or grant relief beyond the breached order.

Availability of an appellate remedy does not by itself bar supervisory jurisdiction under Article 227; interference remains open where a tribunal acts without or in excess of jurisdiction, fails to exercise jurisdiction, or acts perversely causing grave injustice. On that basis, the petition was maintainable. In contempt proceedings, the authority must confine itself to wilful disobedience of the operative order and cannot reopen the merits of the underlying dispute or grant substantive directions beyond that order. A direction affecting the pending interlocutory application and permitting completion of the sale process was therefore beyond contempt jurisdiction and was set aside, while subsequent sale-related steps were left to abide by the interlocutory application.

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Issues: (i) Whether the petition was maintainable under Article 227 of the Constitution of India despite the availability of an appellate remedy before the NCLAT. (ii) Whether, while dealing with contempt applications, the NCLT could issue directions effectively touching the merits of the pending interlocutory application and permit conclusion of the sale process.

Issue (i): Whether the petition was maintainable under Article 227 of the Constitution of India despite the availability of an appellate remedy before the NCLAT.

Analysis: The existence of a statutory appeal is not an absolute bar to the exercise of supervisory jurisdiction under Article 227. Interference remains permissible where the tribunal is shown to have acted without jurisdiction, failed to exercise jurisdiction, or acted perversely, causing grave injustice. The challenge was therefore entertainable if the impugned order was demonstrably beyond jurisdiction.

Conclusion: The petition was maintainable under Article 227.

Issue (ii): Whether, while dealing with contempt applications, the NCLT could issue directions effectively touching the merits of the pending interlocutory application and permit conclusion of the sale process.

Analysis: Contempt jurisdiction is confined to determining wilful disobedience of the operative order and cannot be used to reopen the merits of the original proceedings or to grant substantive relief not contained in the order alleged to have been violated. The impugned direction went beyond that limited jurisdiction by entering upon matters affecting the pending interlocutory application and by directing that the sale process should be concluded. Such a direction was therefore beyond the permissible scope of contempt jurisdiction and liable to be interfered with. At the same time, since third-party rights had intervened, status quo ante was not directed and subsequent steps were left to abide by the result of the pending interlocutory application.

Conclusion: The impugned direction was without jurisdiction and was set aside; the sale-related actions were left to abide by the outcome of the pending interlocutory application.

Final Conclusion: The supervisory jurisdiction was exercised to strike down only the portion of the NCLT's order that transgressed the limits of contempt jurisdiction, while leaving the underlying dispute before the NCLT open for decision on its own merits.

Ratio Decidendi: In contempt proceedings, the adjudicating authority must remain within the four corners of the order alleged to have been breached and cannot travel into the merits of the original dispute or grant substantive directions beyond the scope of that order.

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