Consequential liquidation orders cannot be separately challenged when earlier possession directions are already affirmed and the relief is worked out.

An appeal against a liquidation-compliance order directing handover of possession was held not maintainable where the order was merely consequential to earlier directions already affirmed in appeal and the possession issue had already been worked out. The tribunal noted that the later order had no independent legal existence because possession of the asset had already been taken. The tenant's separate possession-related objections and inter se rights against the auction purchaser were held to lie outside the scope of the liquidation proceedings and could be raised before the appropriate forum. The purchaser's rights were recognised as arising from the sale process and liquidation orders.

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Issues: Whether the appeal against the order directing handover of possession in liquidation proceedings was maintainable when it was only consequential to earlier orders already affirmed, and whether the tenant's independent possession-related objections could be entertained in such proceedings.

Analysis: The impugned order was found to be a continuation of earlier directions requiring handover of possession, and those earlier directions had already been affirmed in appeal. The subsequent order also recorded that possession of the asset had already been taken, so the cause did not survive independently. The tenant's asserted inter se rights against the appellant were held to be outside the scope of the liquidation compliance proceedings and could be pursued before the appropriate forum. The rights of the successful auction purchaser were also recognised as flowing from the sale process and the liquidation orders.

Conclusion: The appeal was not maintainable against the consequential order and was dismissed.

Ratio Decidendi: An appeal does not survive against an order that is merely consequential to earlier orders already confirmed in appeal and that lacks an independent legal existence, especially where the underlying relief has already been worked out.

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