When the extent of property and share of parties is in dispute, a bare suit for permanent injunction is not maintainable without seeking declaration of title. In injunction suits, reference to title is limited only to test possession with semblance of right and cannot substitute a declaratory adjudication of title. Disputes between co-sharers or joint family members regarding extent of property necessarily require declaration of title. Failure of courts below to examine maintainability of injunction suit in the presence of title dispute gives rise to substantial questions of law under Section 100 CPC. Improper appreciation of evidence by courts below itself constitutes a substantial question of law warranting admission of second appeal.

 

Civil Procedure Code, 1908 — Section 100 — Second Appeal — Admission stage

Substantial question of law — Maintainability of suit for permanent injunction — Dispute relating to title and extent — Appreciation of evidence — Appeal admitted.

Where the appellant contended that:

(i) parties are in possession of different extents pursuant to an earlier partition decree and subsequent settlement by elders,
(ii) extent of property is seriously disputed, and
(iii) courts below decreed the suit for bare injunction without considering necessity of declaration of title,

the High Court held that substantial questions of law arise warranting admission of the second appeal.
(Paras 1–6)

---

Suit for Permanent Injunction — Title dispute — Maintainability

Mere injunction suit — When not maintainable — Declaration of title necessary.

When dispute exists regarding:

• extent of property,
• respective shares of parties, and
• title arising from alleged joint family arrangement,

a mere suit for permanent injunction is not maintainable, and the plaintiff ought to seek declaration of title.
(Paras 2–4)

---

Injunction simpliciter — Possession — Semblance of right

In a suit for permanent injunction, reference to title is permissible only to examine whether the plaintiff is in possession with semblance of right and not as an outright trespasser or encroacher.
Any party seeking adjudication of title must necessarily file a suit for declaration of title.
(Para 3)

---

Joint family property — Dispute between co-sharers

Where plaintiff and defendant are step-brothers claiming enjoyment of joint family properties, and the defendant disputes the extent of plaintiff’s share, a suit for injunction alone without declaration of title is legally not maintainable.
(Para 4)

---

Appreciation of evidence — Question of law

Whether the courts below properly appreciated the oral and documentary evidence on record constitutes a substantial question of law in the facts of the case.
(Para 5)

---

Second Appeal — Admission

In view of the substantial questions of law arising from:

• maintainability of injunction suit,
• dispute regarding title and extent, and
• appreciation of evidence,

the Second Appeal was admitted.
(Paras 6–7)

---

RATIO DECIDENDI

1. When the extent of property and share of parties is in dispute, a bare suit for permanent injunction is not maintainable without seeking declaration of title.

2. In injunction suits, reference to title is limited only to test possession with semblance of right and cannot substitute a declaratory adjudication of title.

3. Disputes between co-sharers or joint family members regarding extent of property necessarily require declaration of title.

4. Failure of courts below to examine maintainability of injunction suit in the presence of title dispute gives rise to substantial questions of law under Section 100 CPC.

5. Improper appreciation of evidence by courts below itself constitutes a substantial question of law warranting admission of second appeal.

ADVOCATEMMMOHAN: Property possessed by a female Hindu, even if orig...Property possessed by a female Hindu, even if originally held as a widow’s estate, becomes her absolute property by operation of Section 14(1) of the Hindu Succession Act, 1956. After commencement of the Hindu Succession Act, 1956, the Hindu Women’s Rights to Property Act, 1937 cannot be applied, and any judgment founded on the repealed statute is legally perverse. A female Hindu who becomes absolute owner under Section 14(1) is fully competent to alienate the property by gift, sale, or settlement without consent of reversioners. In a suit for declaration of title and possession, the plaintiff must succeed on the strength of his own title; admissions and absence of documentary proof are fatal. Where long possession under registered gift deeds is admitted and suit is instituted beyond twelve years, the claim is barred under Article 65 of the Limitation Act. Second appellate interference is justified where the First Appellate Court reverses a trial court decree by applying repealed law, ignoring statutory mandate and binding precedent.

ADVOCATEMMMOHAN: Property possessed by a female Hindu, even if orig...: advocatemmmohan Hindu Law — Female Hindu — Absolute ownership — Section 14(1), Hindu Succession Act, 1956 Hindu woman in possession of prop...

Hindu Law — Female Hindu — Absolute ownership — Section 14(1), Hindu Succession Act, 1956

Hindu woman in possession of property prior to 1956 — Enlargement of limited estate — Widow’s estate — Absolute ownership — Effect of repeal of Hindu Women’s Rights to Property Act, 1937 — Applicability after 1956 — Held, widow becomes full owner — Gift executed valid.

Where the widow was in possession of the estate of her deceased husband and son from the year 1941 onwards and continued in possession till after commencement of the Hindu Succession Act, 1956, her limited estate stood enlarged into an absolute estate by operation of Section 14(1) of the Act.
Application of the Hindu Women’s Rights to Property Act, 1937 after 1956 is barred in view of Sections 4 and 14(1) of the Hindu Succession Act.
Gift deeds executed by such female Hindu after commencement of the Act are valid and binding.
(Paras 44–49, 55–59)

---

Hindu Succession Act, 1956 — Sections 4, 14(1) — Overriding effect

Repealed statute — Hindu Women’s Rights to Property Act, 1937 — Cannot be applied after 1956 — Erroneous reliance by appellate court — Perversity.

Once the Hindu Succession Act, 1956 came into force, and particularly after repeal under Section 31, the provisions of the Hindu Women’s Rights to Property Act, 1937 stood excluded.
Application of the repealed enactment by the First Appellate Court was legally impermissible and vitiated the judgment.
(Paras 39–43, 47–49)

---

Hindu Law — Succession — Reversion — Doctrine of reversion — Not applicable after Section 14(1)

Where the female Hindu had become full owner under Section 14(1), the doctrine of reversion stands extinguished and the property does not revert to the heirs of the last male holder.
Claim of reversioners after death of widow held not maintainable.
(Paras 49–55)

---

Civil Procedure Code, 1908 — Section 100 — Second Appeal

Scope — Substantial question of law — Interference permissible where findings are perverse or based on repealed statute.

High Court cannot re-appreciate evidence unless findings of the First Appellate Court are:

(i) contrary to statutory provisions,
(ii) contrary to binding precedents, or
(iii) based on inadmissible or no evidence.

Where the appellate court reversed a well-reasoned trial court decree by applying a repealed statute, the judgment suffers from perversity warranting interference under Section 100 CPC.
(Paras 16–18, 39–40, 60)

---

Limitation Act, 1963 — Article 65

Suit for possession — Knowledge of adverse possession — Limitation begins from date of hostile possession — Admissions binding.

Where plaintiffs admitted:

• execution of registered gift deeds in 1983,
• possession of defendants from 1984–1988 onwards,
• mutation and payment of land revenue by defendants,

and suit for possession was filed in 2001, the claim stood barred under Article 65 of the Limitation Act.
(Paras 20–23)

---

Evidence Act — Admissions — Binding effect

Admissions of plaintiffs in cross-examination regarding possession, mutation, payment of land revenue, execution of gift deeds, and long enjoyment by defendants are substantive evidence and decisive against the plaintiffs’ claim.
(Paras 21–23, 30, 46)

---

Declaratory Suit — Burden of proof

Plaintiff must succeed on strength of own title — Weakness of defendant’s case irrelevant.

In suits for declaration of title and recovery of possession, the burden lies entirely on the plaintiff to establish title by cogent evidence.
Failure to prove own title results in dismissal, irrespective of defects in the defendant’s case.
(Paras 26–33)

---

Civil Suit — Declaration and Possession — Absence of documents

Where plaintiffs failed to file even a single document to establish title or possession, and relied solely on oral evidence contradicted by admissions, the suit was liable to be dismissed.
(Paras 29–33)

---

Gift Deed — Registered settlement — Proof

Registered gift deeds accepted by donees, followed by delivery of possession, mutation in revenue records, issuance of pattadar passbooks and long possession constitute valid transfer of title.
(Paras 34–35)

---

Pleadings — Parties bound by pleadings

Plaintiffs having pleaded exclusive possession of widow from 1941 till her death cannot subsequently contend joint family or coparcenary rights.
(Paras 37–38)

---

Contempt of Courts Act — Order 39 Rule 2-A CPC

No injunction order — No undertaking by contemnors — Contempt not maintainable.

Where no prohibitory order restraining construction was passed and no undertaking was given by alleged contemnors, contempt proceedings are not maintainable.
On setting aside the appellate decree, no executable order survived.
Contempt case liable to be closed.
(Paras 64–68)

---

RATIO DECIDENDI

1. Property possessed by a female Hindu, even if originally held as a widow’s estate, becomes her absolute property by operation of Section 14(1) of the Hindu Succession Act, 1956.

2. After commencement of the Hindu Succession Act, 1956, the Hindu Women’s Rights to Property Act, 1937 cannot be applied, and any judgment founded on the repealed statute is legally perverse.

3. A female Hindu who becomes absolute owner under Section 14(1) is fully competent to alienate the property by gift, sale, or settlement without consent of reversioners.

4. In a suit for declaration of title and possession, the plaintiff must succeed on the strength of his own title; admissions and absence of documentary proof are fatal.

5. Where long possession under registered gift deeds is admitted and suit is instituted beyond twelve years, the claim is barred under Article 65 of the Limitation Act.

6. Second appellate interference is justified where the First Appellate Court reverses a trial court decree by applying repealed law, ignoring statutory mandate and binding precedent.

Overlooking material evidence already on record constitutes an error apparent on the face of the record and justifies exercise of review jurisdiction under Section 114 read with Order 47 Rule 1 CPC. In motor accident claims, the obligation of the Court is to award just compensation, even exceeding the claim amount, when supported by evidence. Where litigation has remained pending for decades, review and modification based on existing material is preferable to remand or reopening of evidence.

Code of Civil Procedure, 1908 — Section 114 — Order 47 Rule 1 — Review — Scope

Power of review is not an appellate power. Review is permissible only on discovery of new and important matter or evidence, or on account of mistake or error apparent on the face of the record, or for any other sufficient reason. Re-appreciation of evidence or rehearing of the matter on merits is impermissible under review jurisdiction.

(Paras 14, 15, 16)

---

Review — Error apparent on face of record — Overlooking material evidence

Where material evidence available on record is overlooked by the Tribunal as well as by the High Court while deciding the appeal, such omission constitutes an error apparent on the face of the record, warranting exercise of review jurisdiction.

(Paras 16–22)

---

Motor Vehicles Act, 1988 — Compensation — Review — Permissibility

In motor accident claims, where important documentary and oral evidence regarding employment and income of the deceased was already on record but was ignored, the High Court is justified in reviewing and modifying its earlier judgment instead of remanding the matter, particularly when the litigation is pending for more than two decades.

(Paras 21–22)

---

Additional evidence — Order 41 Rule 27 CPC — Review stage — Maintainability

Additional evidence under Order 41 Rule 27 CPC can be considered only when the appeal is pending. After disposal of the appeal, additional evidence cannot be introduced by linking it with a review application, as the same amounts to putting the cart before the horse.

(Paras 10–11)

---

Motor accident compensation — Enhancement of claim — Stage of proceedings

Enhancement of claim amount is permissible while the matter is pending. After disposal of the appeal, entertaining an application for enhancement in review proceedings is impermissible and amounts to lack of due diligence.

(Paras 12–13)

---

Motor Vehicles Act, 1988 — Just compensation — Claim exceeding amount claimed

There is no legal bar to awarding compensation in excess of the amount claimed, if the claimants are otherwise entitled to just compensation. The duty of the Court is to determine compensation which appears to be just under Section 168 of the Act.

(Paras 12, 24)

---

Income of deceased — Salary certificate — Appreciation of evidence

Where the widow of the deceased deposed regarding employment and income of the deceased and the salary certificate was marked without dispute, absence of further cross-examination on employment and earnings renders the evidence reliable. Overlooking such evidence constitutes manifest error.

(Paras 18–21)

---

Inquest report — Evidentiary value

Statements recorded in the inquest report regarding occupation and nature of duty of the deceased, entered in due discharge of official functions, constitute important material evidence and cannot be ignored while assessing income.

(Para 21)

---

Future prospects — Addition — Government employment

For a deceased aged between 40–50 years in permanent employment, 30% addition towards future prospects is mandatory as per the principles laid down in Pranay Sethi.

(Paras 23–25)

---

Multiplier — Selection — Sarla Verma principles

Multiplier has to be applied strictly in accordance with the age of the deceased as prescribed in Sarla Verma v. DTC. For the age group of 41–45 years, the appropriate multiplier is 14.

(Paras 23, 25)

---

Consortium — Entitlement — Wife and children

Compensation under the head of loss of consortium is payable not only to the spouse but also to children under the head of parental consortium, in terms of Magma General Insurance Co. Ltd. v. Nanu Ram.

(Para 26)

---

Motor accident compensation — Long pendency — Interest

Considering the long lapse of time in adjudication, interest can be reasonably reduced while enhancing compensation in review proceedings.

(Paras 27–28)

---

RATIO DECIDENDI

1. Overlooking material evidence already on record constitutes an error apparent on the face of the record and justifies exercise of review jurisdiction under Section 114 read with Order 47 Rule 1 CPC.

2. In motor accident claims, the obligation of the Court is to award just compensation, even exceeding the claim amount, when supported by evidence.

3. Where litigation has remained pending for decades, review and modification based on existing material is preferable to remand or reopening of evidence.

After completion of investigation and filing of charge-sheet, bail cannot be denied solely on speculative apprehension of threat to the victim unless supported by concrete material. Objections of the complainant under Section 15-A of the SC/ST (PoA) Act must be substantiated by factual evidence and cannot override the fundamental right to personal liberty. Prolonged judicial custody without demonstrable risk of interference with justice renders refusal of bail arbitrary.

---

SC/ST (PoA) Act — Section 15-A — Right of victim to notice — Compliance — Effect

Issuance of notice to the victim under Section 15-A of the SC/ST (PoA) Act satisfies statutory compliance; however, opposition by the victim must still be supported by material facts. Objections unsupported by evidence cannot by themselves justify denial of bail.

(Paras 6–8)

---

Bail — Custodial detention — Prolonged incarceration — Consideration

Where the accused are in judicial custody for a substantial period and investigation stands concluded, continued detention without cogent reasons amounts to unjustified curtailment of personal liberty.

(Paras 4, 5, 7–9)

---

Bail — Conditions — Safeguards

While granting bail, the Court may impose appropriate conditions including:

• execution of personal bonds and sureties;

• restriction on leaving the country;

• prohibition on intimidating or influencing the victim; and

• liberty to the prosecution to seek cancellation upon violation.

(Para 10)

---

ANALYSIS OF FACTS AND LAW

---

Facts

• FIR registered on 22.09.2025 in Crime No.228 of 2025 of Nandyal Taluk Urban Police Station.

• Alleged offences under:

  • Sections 118(1), 118(2) r/w 5 BNS, 2023, and

  • Sections 3(1)(r), 3(1)(s), 3(2)(va) of the SC/ST (PoA) Amendment Act, 2015.

• Accused (A-1 to A-3) arrested on 02.12.2025 and remanded to judicial custody.

• Bail application under Section 483 BNSS, 2023 dismissed by Special Court on 16.12.2025.

• Sole ground for rejection: apprehension that accused may threaten the victim.

---

Findings of the High Court

1. Investigation completed and charge-sheet filed on 12.12.2025 — no scope for interference with investigation. (Para 5, 7)

2. Victim’s apprehension of threat was not supported by any material indicating intimidation or attempts to cause alarm after registration of FIR. (Para 7)

3. The Special Court relied only on objections filed by the complainant, without factual foundation. (Para 7–8)

4. The predicate offence under Section 118(1) BNS involved injury to the leg and the victim was out of danger. (Para 7)

5. Continued incarceration of the appellants for about 50 days, despite completion of investigation, was unjustified. (Paras 4–9)

---

Error in the Special Court’s Order

The High Court held that:

• refusal of bail solely on speculative apprehension,

• without supporting material, and

• after completion of investigation,

is unsustainable in law.

Accordingly, the impugned order was liable to be set aside.

(Paras 8–10)

---

RATIO DECIDENDI

1. After completion of investigation and filing of charge-sheet, bail cannot be denied solely on speculative apprehension of threat to the victim unless supported by concrete material.

2. Objections of the complainant under Section 15-A of the SC/ST (PoA) Act must be substantiated by factual evidence and cannot override the fundamental right to personal liberty.

3. Prolonged judicial custody without demonstrable risk of interference with justice renders refusal of bail arbitrary.

Arbitration and Conciliation Act, 1996 — Section 9 — Interim measures — Scope While exercising jurisdiction under Section 9 of the Arbitration and Conciliation Act, 1996, the Court must confine itself to interim protection and cannot grant relief in the nature of a final adjudication. Paras 26, 42 Interim mandatory injunction — Grant — Principles An interim mandatory injunction is not a remedy to be granted lightly. It can be granted only when: (i) circumstances are clear; (ii) prima facie material establishes alteration of status quo; and (iii) interests of justice demand restoration of status quo ante. Paras 30–31, 47

Arbitration and Conciliation Act, 1996 — Section 9 — Interim measures — Scope

While exercising jurisdiction under Section 9 of the Arbitration and Conciliation Act, 1996, the Court must confine itself to interim protection and cannot grant relief in the nature of a final adjudication.

Paras 26, 42

---

Interim mandatory injunction — Grant — Principles

An interim mandatory injunction is not a remedy to be granted lightly. It can be granted only when:

(i) circumstances are clear;
(ii) prima facie material establishes alteration of status quo; and
(iii) interests of justice demand restoration of status quo ante.

Paras 30–31, 47

---

Status quo — Meaning

“Status quo” in ordinary legal connotation means the existing state of affairs at a given point of time.

Paras 27–28

---

Status quo ante — Meaning and effect

“Status quo ante” means restoration of the state of affairs existing prior to the current state, and such an order necessarily disturbs the existing possession and operates as a mandatory injunction.

Paras 29–30

---

Status quo ante — Ad-interim stage — Restrictions

Orders directing maintenance of “status quo ante”:

• cannot be passed mechanically,
• cannot be passed without recording reasons, and
• must be supported by prima facie findings justifying restoration.

Paras 30–31, 47

---

Judicial orders — Reasons — Necessity

Reasons are the backbone of judicial orders.
A non-speaking order, or an order without justifiable reasons, cannot be sustained in law.

Paras 32–35

---

Reasons — “Life of law” — Doctrine

When the reason of a law ceases, the law itself generally ceases.
Recording of reasons ensures transparency, fairness, accountability and enables appellate scrutiny.

Paras 32–35

---

Administrative / judicial orders — Requirement of reasoned order

Even administrative or quasi-judicial orders must record reasons.
Judicial orders require an even higher standard of reasoning.

Paras 34–35

---

Orders — Validity — Reasons must be in the order itself

The validity of an order must be judged only on the reasons stated therein.
Reasons cannot be supplied later by affidavit or arguments.

(Mohinder Singh Gill principle)

Paras 39–40

---

Section 9 proceedings — Pending adjudication — Appellate restraint

When the main Section 9 application is pending, appellate court shall not enter into factual controversies which fall within the domain of the Special Judge.

Paras 26, 41–42

---

Lease dispute — Possession — Factual controversy

Whether possession was taken in accordance with lease conditions or statutory procedure is a mixed question of fact and law, which must be decided by the Section 9 Court and not for the first time in appeal.

Paras 36–43

---

Major Port Authorities Act, 2021 — Section 68

Questions regarding applicability of Section 68(1) or 68(3) of the Major Port Authorities Act, 2021 involve factual determination and cannot justify an ad-interim mandatory order without prima facie findings.

Paras 36–43

---

Appeal under Commercial Courts Act — Maintainability

Appeal against an ad-interim order passed under Section 9 of the Arbitration Act is maintainable.

Para 24

---

Bank guarantee principles — Inapplicability

Judgments relating to restraint on invocation of bank guarantees do not govern cases involving ad-interim mandatory injunctions restoring possession.

Paras 48–49

---

FACTS (As recorded by the Court)

Paras 2–15

1. The respondents filed C.A.O.P. Nos. 37 & 38 of 2025 under Section 9 of the Arbitration and Conciliation Act, 1996 before the Commercial Court, Visakhapatnam.

2. The lease dated 02.02.2024 was granted by Visakhapatnam Port Authority for:

   • Kalvani A/c Auditorium

   • Nehru Sports and Cultural Complex

   • Lease period: 10 years.

3. Alleging violations of lease conditions:

   • show-cause notices were issued;

   • bank guarantee was invoked;

   • termination notice dated 10/11-09-2025 issued;

   • right of re-entry exercised.

4. Multiple writ proceedings were filed and disposed of, granting liberty to parties to pursue remedies under the lease deed.

5. Thereafter, Section 9 petitions were filed.

6. During pendency of the petitions, the Special Judge passed an ad-interim order dated 19-12-2025 directing:

“Parties shall maintain status quo ante as on the date of filing of this petition.”

7. The said order was extended till 27-01-2026, when the Section 9 applications were posted for orders.

8. The ad-interim order dated 19-12-2025 was challenged in the present appeals.

---

POINT FOR DETERMINATION

Para 22

Whether the ad-interim order dated 19-12-2025, directing maintenance of status quo ante, is legal and sustainable?

---

ANALYSIS OF LAW

---

1. Nature of the impugned order

Paras 25–26

The impugned order is:

• an ad-interim direction,

• passed pending Section 9 petitions,

• directing restoration of possession by ordering status quo ante.

Such order is in substance a mandatory injunction.

---

2. Meaning of “status quo”

Paras 27–28

Relying on:

• Satyabrata Biswas v. Kalyan Kumar Kisku

• Bharat Coking Coal Ltd. v. State of Bihar

the Court held:

“Status quo” means the existing state of affairs at the given point of time.

---

3. Meaning of “status quo ante”

Paras 29–30

Status quo ante means:

• restoration of the previous state of affairs;

• disturbance of existing possession;

• exercise of mandatory jurisdiction.

---

4. Interim mandatory injunction — governing law

Paras 30–31

Relying on:

Kishore Kumar Khaitan v. Praveen Kumar Singh
(2006) 3 SCC 312

the Court reiterated:

Interim mandatory injunction is granted only when circumstances are clear and justice demands restoration of earlier position.

---

5. Absence of reasons in the impugned order

Paras 32–33

The order dated 19-12-2025:

• assigns no reasons;

• records no prima facie findings;

• does not explain why status quo ante was necessary.

---

6. Reasons — indispensable requirement

Paras 32–35

Relying on:

Assistant Commissioner v. Shukla & Brothers
(2010) 4 SCC 785

the Court held:

• reasons are the life of law;

• non-speaking orders are unsustainable;

• recording of reasons is mandatory even at interim stage.

---

7. Reasons cannot be supplemented later

Paras 39–40

Applying:

Mohinder Singh Gill v. Chief Election Commissioner
(1978) 1 SCC 405

the Court held:

Validity of an order must be judged only by reasons recorded in the order itself.

Arguments of counsel cannot substitute judicial reasoning.

---

8. Lease violation and possession — factual dispute

Paras 36–43

The Court observed:

• whether possession was taken under lease clauses;

• whether Public Premises Act or Section 68 of Major Port Authorities Act applies;

• whether re-entry was lawful,

are mixed questions of fact and law, requiring adjudication by the Section 9 Court.

Such issues cannot justify a blanket mandatory order without findings.

---

9. Undisputed factual position

Para 45

The Court recorded:

1. Possession was taken on 15-12-2025;

2. Respondent was not in possession on 19-12-2025;

3. Impugned order contains no reasons.

---

10. Distinction from bank guarantee cases

Paras 48–49

The judgment in Jindal Steel & Power Ltd. v. Bansal Infra Projects Pvt. Ltd. (2025) 10 SCC 176 was held inapplicable because:

• that case dealt with restraint on bank guarantee;

• present case concerns mandatory restoration of possession.

---

FINAL CONCLUSIONS

Paras 47, 51–53

The High Court held:

1. The impugned order is an ad-interim mandatory injunction.

2. No reasons were recorded to justify restoration of status quo ante.

3. No prima facie findings were made.

4. The order violates settled principles governing interim mandatory relief.

---

FINAL ORDER

• Impugned order dated 19-12-2025 is set aside.

• Section 9 applications shall be decided by the Special Judge on the scheduled date, independently and in accordance with law.

• Appeals allowed.

• No order as to costs.

---

RATIO DECIDENDI

1. An ad-interim order directing “status quo ante” amounts to an interim mandatory injunction.

2. Interim mandatory injunctions cannot be granted without clear reasons and prima facie findings.

3. “Status quo ante” restores possession and therefore cannot be ordered mechanically.

4. Reasons are the life of judicial orders; absence of reasons renders the order unsustainable.

5. Validity of a judicial order must be judged solely on reasons recorded in the order itself.

6. Factual disputes regarding possession and lease violations must be decided in Section 9 proceedings, not by ad-interim directions.