Smt. Dr. Thoyajakshi Bai Sakranaik Vs Patanjali Hospitals Private Limited (NCLAT Chennai)
National Company Law Appellate Tribunal (NCLAT) Chennai Bench has dismissed an appeal filed by Dr. Smt. Thoyajakshi Bai Sakranaik against Patanjali Hospitals Private Limited, upholding an earlier order from the National Company Law Tribunal (NCLT) Bengaluru Bench. The NCLAT’s decision, issued on May 25, 2025, affirms the NCLT’s refusal to grant an interim order to halt a proposed Extraordinary General Meeting (EGM) of Patanjali Hospitals, which was scheduled to consider Dr. Sakranaik’s removal from the company’s directorship.
The case originated from a company petition (No. 127/BB/2023) filed by Dr. Sakranaik under Sections 241 and 242 of the Companies Act, 2013, alleging oppression and mismanagement. Her appeal specifically challenged the NCLT’s order dated May 1, 2025, which declined her request to keep the EGM proposal in abeyance.
The NCLAT emphasized that the grant of an interim order in any judicial proceeding is a discretionary remedy, contingent upon establishing a prima facie case, the existence of a right, and the likelihood of prejudice to the applicant. In this instance, the NCLAT found no legal fault with the NCLT’s decision, citing several reasons for its rejection of the interim relief.
Key Findings and Observations by NCLT (Upheld by NCLAT):
