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ART OF DRAFTING

PLEADINGS
Pradeep. K Mittal
Past Central Council Member
The Institute of Company Secretaries of India,
New Delhi
Advocate
171 Chitra Vihar, Delhi-110092
9811044365/9911044365
BASIC PRINCIPLES OF DRAFTING
ORDER VI OF CODE OF CIVIL PROCEDURE,
1908 (CPC)
RULE 1

PLEADING

WRITTEN REPLICATION/
PLAINT REJOINDER
STATEMENT
PLEADING TO STATE MATERIAL FACTS AND NOT EVIDENCE

Every pleading shall contain only a statement in a concise form of


material facts on which the party pleading relies but not the evidence by
which they are to be proved.

Every pleading shall be divided into paragraphs, numbered


consecutively, each allegation be should be in a separate paragraph.

Dates, sums and numbers shall be expressed in a


pleading in figures as well as in words.
Every pleadings must have the facts and not law. It must state
all the material facts - Order 6 Rule 2 CPC.

   MAYAR ( H . K . ) LTD . AND ORS . VS . OWNERS AND


PARTIES , VESSEL M . V . FORTUNE EXPRESS AND ORS
[AIR 2006 SC 1828]

   RAMESHKUMAR AGARWAL VS . RAJMALA EXPORTS


PVT . LTD . AND ORS .[AIR 2012 SC 1887]
ORDER 6 RULE 14 OF CPC
PLEADING TO BE SIGNED

Every pleading shall be signed by the party and his pleader, if any.
Provided that where a party pleading is, by reason of absence or
for other good cause; unable to sign the pleading, it may be signed
by any person duly authorized by him to sign the same or to sue or
defend on his behalf.
The authorization to sign the pleadings could be either by
a) Board Resolutions in case of body corporate
b) Power of Attorney duly executed.
Before any one proceed to commence drafting, it is absolutely
necessary to gather necessary information by having extensive
discussion with the clients. The information can be gathered by
asking the following questions:
A) WHETHER ALL FACTUAL DETAILS HAVE BEEN
TAKEN OUT:
i) all previous litigation if any before any court of law to
examine as to what was the stand taken by the party before
that court;
ii) all correspondence between the parties;
iii) Whether is there any admission by Respondents on debts
payable Respondent to Petitioner.
B) ALL EVIDENCE NECESSARY FOR DRAFTING

a) Memorandum & Articles of Association


b) Annual Returns certified copies along with proof payment of
fees to MCA;
c) Balance Sheets for the last four years;
d) Criminal complaints/cases against any of the Respondents;
e) Any judgment of court of law convicting the Respondents for
the offence involving Moral Turpitude or any judgment
delivered by any court where the parties are same;
SUSHIL KUMAR SINGHAL Vs. PNB [ 2010(8) SCC
573]
(Moral Turpitude means anything contrary to honesty,
modesty or good morals. It means vileness and depravity.)
f) Copies of Board Resolutions/Forms
C) APPOINTMENT OF ADDITIONAL
DIRECTORS

a) Allege that no notice of Board Meeting was received


b) Check as to whether maximum number prescribed under the
Article allow further appointment of Directors;
c) Allege that there is no tangible need for appointment Of
additional directors;
d) Give the background of additional directors;
e) Attach Form No.32 (now DIR-12)– If filed late, then allege
that
Board Meeting has been shown in the back date
f) Whether approval of any FI/Bank has been obtained;
D) CESSATION OF OFFICE OF EXISTING DIRECTORS

Whether any of the grounds as set out under Sec. 167


Companies Act, 2013
i) Removal under Section 169: Removal of Directors
ii) Contravention of Section 185: Loan to Directors
iii) Contravention of Section 188: Related Party
Transaction
iv) Convicted of offence involving Moral turpitude
a) Section 138 of NI Act
b) Criminal Acts as defined Under IPC
E) Removal of Promoter Directors
a. Non-compliance of Section 169 of the Companies Act,2013
b. No notice of BM/GM
i) UPC is no proof of service of notice;
ii) Proof of dispatch of notice is must;
iii) Extracts of Cash Book showing amt. spent in postage;
iv) Attendance Register;
v) Extracts of the minutes of either BM/AGM/EGM
c. Removal contrary to understanding in family company;
d. Removal against the principle of quasi partnership;
e. Directorial complaints generally not maintainable. In a petition
u/s 397 & 398 of Companies Act, 1956, unless company is not
in the nature of quasi-partnership. Therefore, always allege that
the company is in the nature of quasi-partnership.
F) ILLEGAL TRANSFER OF SHARES / REMOVAL OF
DIRECTORS

a) Annual Return is filed showing that cession of directorship and


transfer of shares held by the promoters;
b) Statutory Returns is not evidence/proof of transfer of
shares/cession of directorship;

 KOBIN PVT. LTD VS. KOBIN INDIA LTD [2005(126)


ComCas675]
 TONY ELECTRONICS LTD 2013 (196) DELHI LAW TIMES
777.
 MANNA LAL KHAITAN AIR 1977 SC 536
The provisions of Section 56 of Companies Act,2013 are
mandatory;
G) INFORMATION CAN BE OBTAINED UNDER
RIGHT TO INFORATION ACT:

a) Under the Passport Act:/Immigration laws:


b) About the ownership of the immoveable
properties;
c) Information from Municipal Corporation of
Delhi/DDA
d) Information about acquisition of shares
involving FEMA;
(H) Allegation that petition is barred
A) Section 8 of Arbitration and Conciliation Act, 1996
B) Section 9 of CPC 1908 Civil Suit for:
C) 430 of Companies Act, 2013
i) wrong removal of director
ii) wrong transfer of shares
CIVIL COURT NOT TO HAVE
JURISDICTION
Section 430 of Companies Act, 2013 provides that, no
civil court shall have jurisdiction to entertain any suit or
proceeding in respect of any matter which the Tribunal or
the Appellate Tribunal is empowered to determine by or
under this Act or any other law for the time being in force
and no injunction shall be granted by any court or other
authority in respect of any action taken or to be taken in
pursuance of any power conferred by or under this Act or
any other law for the time being in force, by the Tribunal
or the Appellate Tribunal.
JUDGMENTS RELATING TO
JURISDICTION
 In the matter of SAS HOSPITALITY PVT. LTD. VS.
SURYA CONSTRUCTIONS PVT. LTD. 2018 SCC
ONLINE DEL 11909 has also held that, (a) NCLT is a
Tribunal which has been constituted to have exclusive
jurisdiction in the conduct of affairs of companies; (b) it has
been vested with powers to pass such order as it may deem fit,
to review and also to punish for contempt; (c) NCLT is
empowered to oversee and supervise the working of the
company and also appoint such persons as may be deemed
necessary to regulate affairs of the company; (d) the powers of
NCLT are wider than that of the Civil Court; and, (e) the bar
under Section 430 is absolute.
 In the matter of DINESH KUMAR v. SINECURE
TECHNOCITY PVT. LTD. & ORS. CS(COMM) NO.242/2019
the Hon’ble High Court of Delhi held that bar of jurisdiction of
the Civil Court would depend upon the nature of the averments in
the plaint.
In the matter of VIJAY CHHIBBER AND ORS. DELHI
GYMKHANA CLUB LTD. CS(OS) 510/2018 the Hon’ble High
Court of Delhi held that Section 241 of the Companies Act, 2013
entitles a member of a company who complains that the affairs of
the company are being conducted in a manner prejudicial to public
interest or in a manner prejudicial or oppressive to him or any
other member or members or in a manner prejudicial to the
interests of the company, to apply to the NCLT. Thus the remedy
for the grievance of mismanagement and oppression would be
before the NCLT.
(I) HOLDING A MEETING WITH THE CLIENTS
AND DO THE CROSS- EXAMINATION & ASK
AS MANY AS QUESTIONS AS YOU CAN SO AS
TON UNDERSTAND HISTORICAL
BACKGROUND OF THE WHOLE CASE.
J) FORMS OF PLEADINGS

a)Form prescribed

b)Set brief description of each of the petitioner and


respondents;

c) Never admit or confess on any points which may go


against you.
d) Narrate the Facts:
i) Determine points/Issues involved
ii) Set the facts on each of the points;

In the absence of pleadings, evidence, if any,


produced by the parties cannot be considered and no
party should be permitted to travel beyond its
pleadings.
 ANIL VASUDEV vs. NARESH KARUSHALI [SCC 2009
SC 310]
 HARI CHAND VS. DAULAT RAM [AIR 1987 SC 94]
e) Examine as to whether the case being set out should
not be contrary to documents being filed by you;
f) Legal clauses / Submission::
i) Cause of action
ii) Limitation:
iii) Jurisdiction:
iv) No previous legal proceedings on same
issue;
v) Prayer
g) Signing of petition on behalf of company, authorization by the
company in favor of MD, Director or Company Secretary.
The petition can be dismissed in absence of authorization
(Order 29 CPC).

h) If the petitioner is a company, then Board Resolution resolving


to file petition must be filed. Similarly, if the petitioner is
either a Trust or Society, Firm, then a resolution resolving to
file a petition and authorizing an officer to sign, verify and
file the petition must be annexed along with the petition.
Whenever any petition is filed under any provisions of
Companies Act, 2013, there must be an affidavit in support of
petition under Order 6 Rule 15 (4) CPC.
i) The Director, by virtue of their office, are not entitle to
file a case
 APPLE VALLEY RESORTS VS. H P ESTATE
ELECTRICITY BOARD [2003 (48) SCL 680 Himachal
Pradesh)]
 RAGHUVIR PAPER MILLS VS. INDIA SECURITIES LTD
[2000 Corporate Law Cases 436].

j) Verification / Affidavit – Petition to be supported


by an affidavit – Order 6 Rule 15 CPC. The Affidavit
must be on Stamp Paper and notarized either by Oath
Commissioner or Notary Public.
K) DOCUMENTS TO BE ATTACHED
a) Memorandum & Articles of Association duly amended;
b) Copy of latest Audited Balance Sheet;
c) Correspondence/Agreement/Documents relied upon;
d) DD payable towards court fees.
e) Paper Book with index duly page numbered;
f) Proof of Service of petition with respective authorities like
RD or ROC wherever necessary;
- Documents to be attached.
- Signature upon the pleadings
- Party
- Pleader
L) WRITTEN STATEMENT/REPLY
Neither the CLB Regulation nor NCLT rules prescribe any proforma for
filing of Written Statement or Reply to the Company Petition or Company
Application. However, the Written Statement or Reply may be in the
following proforma.
a) Preliminary objections raised all legal objections such as
i) Petition is time barred
ii) NCLT has no jurisdiction or jurisdiction is barred
iii) Petition is liable to be dismissed due to fraud being played by the petitioner
iv) Petitioner does not satisfy the fundamental conditions of (a)either
shareholding (b) or requisite number of members- Section 399 of
Companies Act, 1956.
v) Petition is barred by res-judicata- Section 11 of CPC. Nazim Ali vs.
Anjuman Islamia 1993(3) SCC 91.
vi) Similar petition is pending and, therefore, invoke the principle of matter
being sub-judice as per Section 10 of CPC.
b)Petition is not supported by legal and proper affidavit or legal and valid
consent.
c) Issue raised in the petition is already subject matter of arbitration agreement
as provided u/s 8 of Arbitration and Conciliation Act, 1996.
d) In case the petition has been filed by the company, there is no proper board
resolution authorizing the filing of the petition.

Limitation:- Section 3 of Limitation Act;


To decide as a Preliminary Issue –
 OFFICIAL TRUSTEE VS. SACHINDA NATH CHATERJEE [AIR
1969 SC 823].
It is obligatory for any court to see as to whether any suit or any petition,
appeal or application, if filed, after the period of limitation, has to be
dismissed . (Section 3 of Limitation Act)
 Ashok Kr Khurana Vs. Steelman Industries 2000 (85) DLT 398 Delhi
DB
ORDER 8
REPLY ON MERITS CPC

While drafting Written statement, give brief historical background


for easy understanding and comprehension of all issues/
contents/disputes involved in the company petition or points raised
in the written statement.
I. GIVE BRIEF BACKGROUND:
a) Formation of Company
b) Contribution of Respondents in terms of capital, loans, personal
guarantees, mortgage/ hypothecation assets by Respondent, non-
drawl of salary
c) Day to day management with respondents
d) Give historical background of petitioner in terms of finances,
business and personal dealings.
II) Specific denials of the averments made in
petition – Order 8 Rule 5 CPC.

 Every allegation of fact in the plaint if not


denied specifically or by necessary implication, the
averments/pleadings shall be taken to be
admitted – Order and Rule 5.
ARAVALI LEASING LIMITED VS. UNITED
BOTTLES LTD. [1998 CCC PAGE 584]
Evasive denial is no denial –
 LOHIA PROPERTIES (P) LTD. VS. ATMA RAM KUMAR
1993 JT (VOL.5) 223 SC.
RAJ BAHADUR SHARMA VS. UNION OF INDIA 1998
(9) SCC PAGE 458.
 OMN PRAKASH MALHOTRA VS. SHANKAR LAL
AGGARWAL MANU/DE/1322/2011

Evasion and unspecific denial is no denial and is in fact


admission and no further proof is necessary for the party to
lead: Rajiv Saluja Vs. Bharatia Industries DCLR 2002 (II)
Delhi 46
III) After denial, set out your own case
and attach copies of documents,
evidence and paper relied upon in
support of your own case.
AMENDMENT OF PLEADINGS
If any party to the petition wishes to
amendment its (a) Petition (b) Reply/Written
Statement (c) Rejoinder (d) Sur-Rejoinder,
party can move an application under Order 6
Rule 17 CPC read with Section 151 CPC.
The application can be at any time before the
final arguments commenced;
Any amendment amounting to (a) a totally new and
inconsistent case cannot be allowed, by way of
amendment; (b) different and fresh cause of action, (c)
any substitution of an entirely new case in the place of
the previously pleaded case (d) an amendment which
seeks to bring allegations of fraud when the main petition
is silent (e) introduce a new set of ideas to the prejudice
of any right acquired by any party on account of lapse of
time; is impermissible under Order 6 Rule 17 of CPC and
beyond the powers of the CLB/NCLT
Pleading would only be amended if it is to substantiate,
elucidate and expand the pre-existing facts already
contained in the original pleadings.

(i) Municipal Corporation of Greater Bombay v.


Lala Panchamand Ors.MANU/SC/0284/1964,
(ii)Ajendaprasadji N. Pande v. Swami
Keshavprakeshdasji N. MANU/SC/8760/2006
(iii)B.K. Narayana Pillai v. Parameshwaran
Pillai MANU/SC/0775/1999
(iv) A.K. Gupta & Sons Ltd. v. Damodar
Valley Corporation MANU/SC/0014/1965
(v)The Madras High Court held in
Kumaraswami Gounder v. D.R. Nanjappa
Gounder MANU/TN/0224/1978
(vi)Anil Vasudev vs. Naresh Khushali
Shigoankar MANU/SC/1483/2009.
Now, it is well settled that leave to amend is always granted
unless the court be satisfied that the party applying is acting
mala fide, or that by his blunder he has caused injury to his
opponent which cannot be compensated by an order for
costs. And further, leave is granted however negligent or
careless the first omission may have been, and however late
the proposed amendment, provided it can be given without
injustice to the other side:

JAI JAI RAM MANOHAR LAL V. NATIONAL BUILDING


MATERIAL SUPPLY, GURGAON, MANU/SC/0016/1969
It has also been said that courts do not exist
for punishing the parties and that rules of
procedure are not framed to defeat justice:
PATHIKONDA GOPALA RAO V. NAGIR PEDDA KITAMMA,
MANU/AP/0036/1955 : AIR1955AP138.
The Supreme Court has held that even the admission can be
withdrawn.

MANU/UP/0746/2004, MANU/SC/1017/1995 (para 4),


MANU/PH/0715/2005 (para 11)and MANU/SC/0019/1983
The power to grant amendment of pleadings is intended to serve
the ends of justice and is not governed by any narrow or
technical limitations. Reliance was placed on the case law
reported at MANU/SC/0016/1969 : AIR 1969 SC 1267. The
same was held in the matter of B. LALITHAMMA AND
OTHERS VS. SIDDAGANGAIAH AND OTHER
MANU/KA/1840/2019.
Amendment barred by law – still allowable.
In Ragu Thilak D. John v. S. Rayappan And
Others - MANU/SC/0057/2001  : (2001) 2 SCC
472, the Supreme Court held that where it is
arguable that the relief sought by way of
amendment would be barred by the law of
limitation, the amendment should still be allowed
and the disputed matter made the subject-matter
of an issue. 
In Pankaja And Another v. Yellappa (Dead) By
LRs And Others - MANU/SC/0590/2004  : (2004)
6 SCC 415, the Supreme Court held that even where
the relief sought to be added by amendment is
allegedly barred by limitation, there is no absolute
rule that amendment in such a case should not be
allowed and that an amendment sub serving the
ultimate cause of justice and avoiding further
litigation should be allowed.
ORAL/WRITTEN ARGUMENTS

A) As a general rule, a petitioner is bound by his


pleadings and should not be allowed to set up a case
absolutely new case.
OM PRABHA JAIN VS. ABNASH CHAND [AIR 1968
SC 1083]
1. Select first the point on which there is
least dispute.
2. Arguments before the Judges are not the same as
platform oratory. The force of an argument lies in
the reasons behind it.
3. Facts should be stated with clearness, directness,
& never with dullness. No beating about the bush.
4. It is the soundness of evidence and not eloquence
that wins the cases;

5. Avoid abusive language and it never pays;

6. Make your own case by your own side’s evidence.


At the same time, weakness of the other side’s
evidence to be highlighted.
7. Take out the entire law, Law dictionary, Legal
Maxim,
8. Take out Govt. Circulars, Clarifications Answers to
frequently Asked Questions published by the
Department; The Circular binds the Dept. but not
quasi-judicial authority They can always different
view.
9. Never try to confuse the Judge but only opposite
counsel.
WRITTEN ARGUMENTS

A) First find out the issues involved in the case:

B) On each issue , set out your pleadings and


documents with relevant page no and also
cases relied upon by you.

C) Oral or documentary evidence led by both the


parties;
D) Critical analysis of the evidence with the
provisions of India Evidence Act;

E) Case applicable

F) Conclusions.
Important Principles of law

FINAL RELIEF CANNOT BE GRANTED AT INTERIM


STAGE

The Supreme Court reported in MANU/SC/0258/1995 : 1995(3)


SCC 257 being Bank of Maharashtra v. Race Shipping and
Transport Co. Pvt. Ltd. and Anr. wherein it has been held that the
Court should deprecate the practice of granting interim orders
which practically give the principal relief sought in the petition
for any better reason than that a prima facie case has been made
out without being concerned about the balance of convenience etc.
WHERE LAW IS SILENT, YET REMEDY MUST BE GIVEN BY
COURT:

In M.V. Elisabeth and Ors. v. Harwan Investment and Trading


Pvt. Ltd. 1993 Supp (2) SCC 433, Supreme Court observed that
where substantive law demands justice for the aggrieved party and
the law does not provided the remedy, it is the duty of the Court to
devise procedure by drawing analogy from other systems of law and
practice. Similarly, in Dhanna Lal v. Kalawatibi and Ors.
MANU/SC/0565/2002 : (2002) 6 SCC 16, the Supreme Court
observed that wrong must not be left unredeemed and right not left
unenforced.
WAIVER AND ACQUISCENCE:
 
U.P. Jal Nigam v. Jaswant Singh
MANU/SC/5073/2006 : (2006) 11 SCC 464
laying down the principles of acquiescence and
holding that it is unjust to give a claimant the
remedy where, by his conduct, he has done that
which might fairly be regarded as equivalent to a
waiver.
THE FIGURES SHOWN IN INCOME TAX RETURN
IS ADMISSION:

The Supreme Court in the case of Uttam Singh Dugal


& Co. Ltd. v. Union Bank of India
MANU/SC/0485/2000 : [2000] 39 CLA l/[2000] 102
Comp Case 118/[2000] 7 SCC 120, has held that the
income-tax returns showing transfer of shares of the
petitioners is an admission, thereby by virtue, of the
said admission, the petition is to be rejected on
admissions as per law laid down under Order 12, Rule
6 of the Code of Civil Procedure.
  
IMPORTANT POINTS
i) Court should not set up a case – which was never
presented by the parties. SHEODHARI VS. SURAJ
PRASAD AIR 1954 SC 758.
ii) Frauds avoids all judicial acts including judgments
and decree. Even judgment or decree passed by court,
in pursuance of practice of fraud, could be set aside
and recalled by any lower court or superior court.
S.P.CHENGALVARYA NAIDU VS. JAGANNATH
1994 (1) SCC 1.
In petition under Section 397 and 399 of the Companies
Act, 1956, the Company Law Board direct the (i)
Respondents directors to restore the funds so siphoned off
to the company (ii) appointment of independent director
(iii) declaring appointment of directors as illegal (iv)
restoring the directorship of those directors who have been
illegally removed. RAMESH CHANDER BAMMI VS.
PINDI ROADLINKS (P) LTD [2007 (81) CLA 97 CLB.]
 
In a petition for oppression and mismanagement,
after giving of consent by members, if the consent is
withdrawn and the remaining petitioner fell below
10%, the petition would not be maintainable.
However, the petition would be maintainable only if,
after filing of petition, the Company issues Bonus
Shares or there is a reduction of paid-up share capital
and the holding of Petitioner is reduced below 10%.
AJIT KUMAR GUPTA VS.. COMPANY LAW
BOARD 2008 (82) CLA 1 (ALLAHABAD.
 The CLB set aside allotment of shares – co
deprived off of funds, petitioner to now funds for
allotment of shares or long term funds to the company
– company now not deprived of working capital.
ABP(P) LTD VS. UNITED NEWS OF INDIA
2008(83)CLA 408 CLB.
 
 The Directorial complaints not to be agitated unless
company is closely held, quasi-partnership.
KAREDIA SURYANARAYANA VS. SRI RAMDAS
MOTOR TRANSPORT LTD 1999(35) CLA 117
CLB.
APPEAL UNDER COMPANIES ACT,
2013
Under Companies Act, 2013 there are two types of appeal,
one lies from the order of National Company Law
Appellate Tribunal (NCLT) to National Company Law
Appellate Tribunal (NCLAT) and the other lies from
order of NCLAT to Supreme Court.
Though Appeal has not been defined under Companies
Act, 2013. Yet an application by a party to an appellate
Court/Tribunal, asking it to set aside or revise a decision
of a subordinate court, is an appeal. [Judicial Dictionary]
APPEAL BEFORE APPELLATE
TRIBUNAL
Section 421 of the Companies Act, 2013 elucidates that an
appeal can be filed by Any person aggrieved by an order
of the Tribunal may prefer an appeal to the Appellate
Tribunal.
The Appellate Tribunal shall, after giving the parties to the
appeal a reasonable opportunity of being heard, pass such
orders thereon as it thinks fit, confirming, modifying or
setting aside the order appealed against. All such decision
shall be binding on both the parties.
LIMITATION IN MATTERS OF
APPEAL
According to Section 421 of the Companies Act, 2013,
every appeal shall be filed within a period of forty-five days
from the date on which a copy of the order of the Tribunal is
made available to the person aggrieved.
It has been further provided that the Appellate Tribunal may
entertain an appeal after the expiry of the said period of
forty-five days from the date aforesaid, but within a further
period not exceeding forty-five days, if it is satisfied that the
appellant was prevented by sufficient cause from filing the
appeal within that period. This provision has been strictly
applied by the Tribunals
JUDGMENTS RELATING TO
LIMITATION
 In the matter of UNION OF INDIA v. POPULAR
CONSTRUCTION CO. MANU/SC/0613/2001 it was held by
the Hon’ble Supreme Court of India that when the legislature
prescribed a special limitation for the purpose of appeal, the
court cannot entertain an appeal beyond the extended period.
 v  Further in the matter of JITENDRA VIRMANI v. MRO-
TEK REALTY LIMITED AND OTHERS
MANU/NL/0021/2017 the court observed that the applicant
has not explained the delay and laches on his part. It has not
explained that why the appeal was not filed within 45 days of
receipt of the certified copy of the judgment.
In the matter of ROHAN PACKAGING
PRODUCTS LIMITED v. LAKSHMICHAND
GIDWANI MANU/NL/0237/2018 the Hon’ble
NCLAT, Delhi rejected the Appeal on the ground that
the Appeal cannot be condoned and is barred by
limitation.
 Also, in the matter of BENGAL DRUGGIST AND
CHEMICAL ASSOCIATION v. KALYAN
CHOWDHARY MANU/SC/0099/2018 the Hon’ble
Supreme Court of India observed that to state that after
such 45 days, this Tribunal cannot condone delay.
APPEAL TO SUPREME COURT
Section 423 of the Companies Act, 2013 articulates that
any person aggrieved may file an appeal to the Supreme
Court within sixty days from the date of receipt of the
order of the Appellate Tribunal to him on any question of
law arising out of such order.
However, the Supreme Court may, if it is satisfied that the
appellant was prevented by sufficient cause from filing the
appeal within the said period, allow it to be filed within a
further period not exceeding sixty days.
Thank You

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