Court-confirmed liquidation sales may be examined for fraud or irregularity even at the instance of a non-aggrieved person.

Where an official liquidator's sale is conducted under court sanction and remains subject to court confirmation, the court may scrutinise the sale for fraud, irregularity, misconduct, or inadequacy of price before ratification. Its supervisory power over an officer of the court is not confined to complaints by a person formally shown to be aggrieved, and it may order a summary inquiry when such allegations are brought to its notice. The question of locus standi may therefore be unnecessary at the inquiry stage if the challenge is directed to the integrity of the sale process.

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Issues: Whether the court could entertain and inquire into a petition challenging an official liquidator's sale on allegations of irregularity and fraud, even if the applicant was not shown to be a "person aggrieved" under the Companies Act.

Analysis: The sale by the official liquidator had been conducted with the court's sanction and was expressly subject to confirmation by the court. The official liquidator, being an officer of the court, could not have his act ratified without the court first satisfying itself that the sale was free from misconduct, irregularity, fraud, or inadequacy of price. The court's power to scrutinise the conduct of its officer was not confined to complaints by an aggrieved or interested person, and it could hold a summary inquiry when such allegations were brought to its notice. On that basis, the question whether the applicant was a person aggrieved became unnecessary for decision.

Conclusion: The petition challenging the sale was maintainable for inquiry, and the preliminary objection that the applicant lacked locus standi failed.

Final Conclusion: The appeal could not succeed because the lower court was right in directing an inquiry into the allegations before confirming the sale.

Ratio Decidendi: Where a sale by an official liquidator is expressly subject to court confirmation, the court may, in exercise of its inherent jurisdiction and supervisory control over its officer, inquire into allegations of fraud or irregularity brought to its notice even by a stranger or non-aggrieved person.

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