Assigned winding-up jurisdiction extends to all later applications, allowing direct filing before the Additional District Judge.

Where the Companies Act requires subsequent winding-up proceedings to continue in the District Court, a valid assignment by the District Judge to an Additional District Judge under the Punjab Courts Act, 1918, as amended, allows the transferee court to act as the District Judge for that case. The deeming fiction gives the Additional District Judge co-equal authority over the assigned winding-up matter, so jurisdictional objection fails. Once the liquidation proceedings are validly assigned, all subsequent applications arising from that case, including an application under section 446(2), may be filed directly before the Additional District Judge without routing them again through the District Judge.

---

---

Issues: (i) Whether, after the High Court directed subsequent winding-up proceedings to be had in the District Court, the District Judge could validly make over the case to an Additional District Judge and that court could exercise jurisdiction under the Companies Act. (ii) Whether an application under section 446(2) of the Companies Act could be presented directly to the Additional District Judge once the liquidation proceedings had been assigned to him.

Issue (i): Whether, after the High Court directed subsequent winding-up proceedings to be had in the District Court, the District Judge could validly make over the case to an Additional District Judge and that court could exercise jurisdiction under the Companies Act.

Analysis: Section 435 of the Companies Act requires subsequent winding-up proceedings to be had in the District Court, and section 2(14) defines the District Court as the principal civil court of original jurisdiction. The Punjab Courts Act, 1918 as amended in 1963 empowered the District Judge to assign cases and functions to an Additional District Judge and provided that, while dealing with cases so made over, the Additional District Judge shall be deemed to be the Court of the District Judge. The statutory deeming fiction removed the earlier difficulty arising from the unamended law and established that, once a case is transferred or assigned, the Additional District Judge acts as a court of co-equal authority for that matter.

Conclusion: The objection to jurisdiction failed, and the Additional District Judge had jurisdiction to deal with the transferred winding-up proceedings.

Issue (ii): Whether an application under section 446(2) of the Companies Act could be presented directly to the Additional District Judge once the liquidation proceedings had been assigned to him.

Analysis: After valid assignment of the winding-up case, all subsequent proceedings arising out of that case travelled with the transfer. The authority to deal with those proceedings was not confined to routing each application through the District Judge again. The direct presentation of the petition under section 446(2) was therefore competent because the assigned court possessed the same powers in relation to that case as the District Judge himself.

Conclusion: The direct filing of the section 446(2) application before the Additional District Judge was valid.

Final Conclusion: The appeals were rejected, and the transfer-based jurisdiction of the Additional District Judge to continue and manage the winding-up proceedings was upheld.

Ratio Decidendi: Where the governing procedural statute authorises the District Judge to assign a matter and deems the Additional District Judge to be the District Judge for the assigned case, the transferee court acquires full jurisdiction to hear all subsequent proceedings in that matter, including applications filed directly in the assigned case.

---