Company investigation order is not a Letters Patent judgment because it is only a preliminary fact-finding direction.

An order directing investigation into a company's affairs under section 237 of the Indian Companies Act, 1913 is only a preliminary fact-finding measure through inspectors. It does not finally determine the rights of the company or its directors, does not terminate the proceedings, and does not affect the merits of the dispute. Because the order is interlocutory and investigative in character, it does not satisfy the settled test of a judgment under clause 15 of the Letters Patent and is therefore not appealable.

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Issues: Whether an order directing investigation into the affairs of a company under section 237 of the Indian Companies Act, 1913 amounts to a judgment appealable under clause 15 of the Letters Patent.

Analysis: An order under section 237 only authorises a preliminary investigation by inspectors in the nature of a fact-finding commission. The court's direction does not finally adjudicate the rights of the company or its directors, does not terminate the proceedings, and does not itself affect the merits of the controversy. The investigation may or may not lead to further action, and the company can have no grievance unless and until such further consequences arise. An order having such interlocutory and investigative character does not satisfy the settled tests of a judgment under clause 15.

Conclusion: The order directing investigation is not a judgment within clause 15 of the Letters Patent and is not appealable. The appeal fails.

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