New Delhi, April 28 -- The recent pronouncement of the National Company Law Tribunal (NCLT), New Delhi, in All About Health India Pvt Ltd and Others is instructive-not so much for its outcome, but for how it was framed.

Although styled with citations from the Supreme Court, references to constitutional expectations from tribunals and an extended discourse on the Issue, Rule, Analysis and Conclusion (IRAC) method of dissecting legal issues as well as ratio decidendi (the underlying principle of a reason-based decision), the document is not a judgment. It is a procedural order under Section 230 of the Companies Act, 2013, allowing stakeholder meetings to be dispensed with for an uncontested amalgamation between wholly owned subsidiaries. ...