SATISH CHURAN LAW vs H. K. GANGULY

The Supreme Court held that the ex-parte order under Section 477 of the Companies Act, 1956, allowing the examination of an ex-director by the Official Liquidator, was not final and could be modified or vacated if obtained through misstatement of facts. The Court emphasized that the primary test for such orders is whether they are just and beneficial to the company's business. However, it ruled that the appellant had no right to inspect the signed statement of the liquidator, as it was confidential and did not form part of the liquidation proceedings.