An order merely enforcing earlier unchallenged directions causes no appealable prejudice.

Respondent No. 1, Loveleen Dhaliwal Singla, instituted Company Petition No. 16/CHD/2025 under Sections 241–242 read with Sections 94, 96, 101, 136, 180, 173 and 447 of the Companies Act, 2013, alleging oppression and mismanagement in the affairs of LSR Infracon Pvt. Ltd. and seeking, inter alia, restraints against the company’s directors, disclosure of transactions, recovery of allegedly diverted funds, and other consequential reliefs.

In Company Application No. 126(CH)/2026, Respondent No. 1 sought directions to the District Authorities of various States and Chandigarh to assist in securing physical possession of the company’s plant and machinery, and directions to the appellant and Amit Singla to disclose the machinery’s locations and refrain from removing or dealing with it.

The NCLT had earlier directed the directors to disclose the company’s machinery, its locations and descriptions, including by orders dated 4 June 2026 and 7 July 2026.

Those orders were not challenged by the appellant.

By order dated 30 July 2026, the NCLT issued directions substantially intended to secure compliance with the earlier orders, including confirmation of the machinery list, specification of serial numbers, and disclosure of any sale or dealings concerning the machinery.

Whether the appellant could challenge the NCLT’s order dated 30 July 2026 when the directions therein substantially enforced or implemented the earlier orders dated 4 June 2026 and 7 July 2026, which had not been challenged?

Whether the impugned order caused any crystallised legal prejudice or affected any vested right of the appellant so as to make the appeal maintainable?

Whether a court or tribunal order may be disregarded or resisted on the ground that the original direction was legally erroneous, without first challenging that direction through appropriate proceedings?

The proceedings arose under Sections 241–242 of the Companies Act, 2013, which empower the NCLT to grant relief against oppression and mismanagement.

Rule 11 of the NCLT Rules, 2016 preserves the Tribunal’s inherent powers to pass orders necessary to secure the ends of justice.

The Court applied the principle that a subsisting order of a competent court or tribunal must be obeyed unless it is stayed, modified or set aside through appropriate legal proceedings.

Relying on Commissioner, Karnataka Housing Board v. C. Muddaiah, (2007) 7 SCC 689, the Court held that non-compliance cannot be justified by contending that the original direction ought not to have been issued; permitting such conduct would undermine the rule of law and administration of justice.

The NCLAT held that the impugned order did not create a new substantive obligation but merely prescribed steps for implementing the earlier directions requiring disclosure of the company’s machinery and its locations.

Since the appellant had not challenged the orders dated 4 June 2026 and 7 July 2026, he could not indirectly question their validity while appealing against an order enforcing them.

The Tribunal also noted that the appellant and Amit Singla were allegedly in control of the company’s affairs and machinery records, making the direction for disclosure factually justified.

The impugned order did not adjudicate the allegations of oppression, mismanagement or diversion of assets on merits, nor did it determine the appellant’s substantive rights.

Consequently, the appellant could not demonstrate any crystallised prejudice or infringement of a vested right.

The Court further held that the impugned order caused no crystallised prejudice to the appellant and did not finally adjudicate any issue on merits.

All pending interlocutory applications were closed.