Report No. 62
7.17. Section 22A.-
There is a verbal point concerning section 22A, under which, after the deposit of a sum by an employer as compensation for injury resulting in death, the Commissioner has power to require the employer to make a further deposit. In sub-section (2) of the section, such a determination of the Commissioner is described as an "award". But, everywhere else in the Act, the word used is "order". The use of a different word is not appropriate, and, in fact, has created some controversy in another field, namely, whether1 the decision of the High Court under section 30 on appeal from an order of the Commissioner is a "judgment" within clause 15, of the Letters Patent.
1. See Rajvayi v. Mackinon Mackenzie & Co., AIR 1970 Born 278 (283) paras. 14 & 15.