M/S. Brahmaputra Concrete Pipe ... vs The Assam State Electricity Board

The Supreme Court addressed the refusal of the Registrar to register curative petitions under Rule 5 of Order XV of the Supreme Court Rules, 2013, holding that such petitions must specifically state that grounds were taken in the prior review petition, which was dismissed in open court. The Court upheld the Registrar's decision, affirming that the curative petitions were not maintainable as the underlying review petitions were not dismissed by circulation as required by Rule 2(1) of Order XLVIII. The Court reiterated that the Interest on Delayed Payments to Small Scale and Ancillary Industrial Undertakings Act, 1993 does not apply to transactions prior to its operational date of 23.09.1992, thus confirming the High Court's dismissal of the appellant's suit.