Saturday, February 25, 2017

PRIVATE LAW REVIEW



Sasi K.G.

01. INTRODUCTION

Administrative law is the body of law that governs the activities of administrative agencies of governmentGovernment agency action can include rulemakingadjudication, or the enforcement of a specific regulatory agenda. Administrative law is considered a branch of public law. As a body of law, administrative law deals with the decision-making of administrative units of government (for example, tribunalsboards or commissions) that are part of a national regulatory scheme in such areas as police lawinternational trademanufacturing, the environmenttaxationbroadcastingimmigration and transport. Administrative law expanded greatly during the twentieth century, as legislative bodies worldwide created more government agencies to regulate the social, economic and political spheres of human interaction.

02. JUDICIAL REVIEW IN ADMINISTRATIVE ACTION

Before entering into the topic, we must be familiar with some basic concepts of Administrative Law.

01. Administrative Law

01. Definitions of Administrative Law

An online dictionary defines Administrative Law as[i];
1. Body of rules, regulations and orders formulated by a government body (such as an environment management agency) responsible for carrying out statute law.
2. Legal rules and principles on which courts act in controlling the exercise of statutory powers of adjudication and rule making by public authorities (other than judiciary and legislature).
It is difficult to evolve a scientific precise and satisfactory definition of administrative law. Many jurist have attempted to define it. But none of the definitions has completely demarcated the nature, scope and contents of Administrative Law. Either the definitions are too broad and include much more than what is necessary or they are too narrow and do not include all the necessary contents.
Definition by Ivor Jennings
According to Ivor Jennings in his "The law and the constitution, 1959", "administrative law is the law relating to the administrative authorities".
This is the most widely accepted definition, but there are two difficulties in this definition.
(1) It is very wide definition, for the law which determines the power and functions of administrative authorities may also deal with the substantive aspects of such powers.
For example:- Legislation relation to public health services, houses, town and country planning etc.. But these are not included within the scope and ambit of administrative law, and
(2) It does not distinguish administrative law from constitution law.
Definition by K. C. Davis
According to K. C. Davis, "Administrative law is the law concerning the powers and procedures of administrative agencies, including especially the law governing judicial review of administrative action".
Definition by Prof. Wade
According to Wade (Administrative Law, 1967) any attempt to define administrative law will create a number of difficulties. But if the powers and authorities of the state are classified as legislative, administrative and judicial, then administrative law might be said "the law which concerns administrative authorities as opposed to the others".
There are some difficulties with this definition. It falls to distinguish administrative law from constitutional law Like Jennings definition mentioned above, this is also very wide definition. It includes the entire legal field except the legislature and the Judiciary. It also includes the law of local government. It is also said that it is not possible to divide completely and definitely the functions of legislative, executive and judiciary.
It is very difficult to say precisely where legislation ends and administrative begins. Though enacting a law is function of the legislature the administrative authorities, legislate under the powers delegated to them by the legislature and this delegated legislation is certainly a part of administrative law.
Definition by Jain and Jain
According to Jain and Jain, "Administrative law deals with the structure, powers and function of the organs of administration, the limits of their powers, the methods and procedures followed by them in exercising their powers and functions, the method by which their powers are controlled including the legal remedies available to a person against them when his rights are infringed by their operation".
Administrative law, according to this definition, deals with four aspects:-
It deals with composition and the powers of administrative authorities.
It fixed the limits of the powers of such authorities.
It prescribes the procedures to be followed by these authorities in exercising such powers and,
It controls these administrative authorities through judicial and other means.
Definition by Griffith and Street
According to Griffith and Street, (Principles of administrative law, 1963), the main object of Administrative law is the operation and control of administrative authorities, it must deal with the following three aspects:-
What are the limits of those powers?
What sort of power does the administration exercise?
What are the ways in which the administrative is kept within those limits?
Improvement to Griffith and Street's Definition by Indian Law Institute
According to the Indian Law Institute, the following two aspects must be added to have a complete idea of the present-day administrative law:-
What are the procedures followed by the administrative authorities?
What are the remedies available to a person affected by administration?
Definition by Garner
According to Garner, administrative law may be described as "Those rules which are recognized by the court as law and which relates to and regulate the administration of government."
Modern Definition
Administrative Law is that branch of the law, which is concerned, with the composition of powers, duties, rights and liabilities of the various organs of the Government.

02. Scope of Administrative Law

The emergence of the social welfare has affected the democracies very profoundly. It has led to state activism. There has occurred a phenomenal increase in the area of sate operation; it has taken over a number of functions, which were previously left to private enterprise. The state today pervades every aspect of human life. The functions of a modern state may broadly be placed into five categories, viz, the state as:-
1. protector,
2. provider,
3. entrepreneur,
4. economic controller and
5. arbiter.
Administration is the all-pervading feature of life today. The province of administration is wide and embrace following things within its ambit:-
1. It makes policies,
2. It provides leadership to the legislature,
3. It executes and administers the law and
4. It takes manifold decisions.
5. It exercises today not only the traditional functions of administration, but other varied types of functions as well.
6. It exercises legislative power and issues a plethora of rules, bye- laws and orders of a general nature.
The advantage of the administrative process is that it could evolve new techniques, processes and instrumentalities, acquire expertise and specialization, to meet and handle new complex problems of modern society.
Administration has become a highly complicated job needing a good deal of technical knowledge, expertise and know-how. Continuous experimentation and adjustment of detail has become an essential requisite of modern administration. If a certain rule is found to be unsuitable in practice, a new rule incorporating the lessons learned from experience has to be supplied.
The Administration can change an unsuitable rule without much delay. Even if it is dealing with a problem case by case (as does a court), it could change its approach according to the exigency of the situation and the demands of justice. Such a flexibility of approach is not possible in the case of the legislative or the judicial process. Administration has assumed such an extensive, sprawling and varied character, that it is not now easy to define the term “administration” or to evolve a general norm to identify an administrative body. It does not suffice to say that an administrative body is one, which administers, for the administration does not only put the law into effect, but does much more; it legislates and adjudicates. At times, administration is explained in a negative manner by saying that what does not fall within the purview of the legislature or the judiciary is administration.

02. Administrative Action

Administrative action is the residuary action which is neither legislative nor judicial. It is concerned with the treatment of a particular situation and is devoid of generality. It has no procedural obligations of collecting evidence and weighing argument. It is based on subjective satisfaction where decision is based on policy and expediency. It does not decide a right though it may affect a right. However, it does not mean that the principles of natural justice can be ignored completely when the authority is exercising “administrative powers”. Unless the statute provides otherwise, a minimum of the principles of natural justice must always be observed depending on the fact situation of each case.
In case A.K. Kraipak v. Union of India[ii] , the Court was of the view that in order to determine whether the action of the administrative authority is quasi-judicial or administrative, one has to see the nature of power conferred, to whom power is given, the framework within which power is conferred and the consequences.
Administrative action may be statutory, having the force of law, or non-statutory, devoid of such legal force. The bulk of the administrative action is statutory because a statute or the 
Constitution gives it a legal force but in some cases it may be non-statutory, such as issuing directions to subordinates not having the force of law, but its violation may be visited with disciplinary action. Though by and large administrative action is discretionary and is based on subjective satisfaction, however, the administrative authority must act fairly, impartially and reasonable.
Grounds for Judicial Review of Administrative Actions are
1. Illegality 
2. Irrationality
3. Procedural impropriety
4. Proportionality

03. Judicial Review

In 1610, in Dr Bonham case[iii] when Lord Chief Justice Coke of England declared an Act of Parliament which had put its seal on the Charter of Royal College of Physics as void, he gave effect to the principle that an interested person being a beneficiary, cannot be a prosecutor and a judge at the same time. Royal College was a society in whose favour the Royal Charter was given. Under the Charter the society was authorised to impose fine on the member - violator of the bye-laws/rules of the society. In the fine imposed and collected by the society from such a member it had one-half share.
Dr Bonham who was fined by the society for violation of its rules and was imprisoned for non-payment of fine, challenged the validity of the action of the society. Chief Justice Coke declared the Act as void, the impugned action illegal and ordered his release. This case may be said to be the beginning of the principle of judicial review of the legislation. It may be noticed here that after the English revolution of 1688, supremacy of Parliament became the hallmark of the unwritten Constitution of the U.K. Perhaps, for that reason, the doctrine of judicial review of parliamentary legislation did not develop in the U.K. for over a century. However, with reference to legislation of colonies, this principle was applied and in that context, the English courts developed it later. In countries having a written Constitution, the position is somewhat different. The principle of judicial review gained firm ground in the U.S.A. in the beginning of the 19th century. Though the doctrine of separation of powers is incorporated in the Constitution of the United States, there is, however, no conferment of express power of judicial review of legislation by the Congress on the Supreme Court of the United States. That principle was ingrained by Chief Justice Marshall of the Supreme Court of the United States in the famous case of Marbury v. Madison[iv] holding:
"Certainly, all those who have framed written Constitutions contemplate them as forming the fundamental and paramount law of the nation, and consequently, the theory of every such Government must be, that an Act of the legislature, repugnant to the Constitution, is void. This theory is essentially attached to a written Constitution, and is, consequently, to be considered, by this Court, as one of the fundamental principles of our society."
The elections of 1800 in the U.S.A. resulted in change of the President. In February 1801, about 200 years ago Marbury, along with 41 persons, was appointed as Justice of Peace for a period of five years by the outgoing President, John Adams (they were called midnight appointees). The Senate confirmed the appointments and the warrants of appointment were signed and sealed. In March 1801, Thomas Jefferson took charge as the President of the U.S.A. At his instance, the Secretary of State, James Madison, declined to deliver the warrant of appointments to Marbury and others who sought a writ of mandamus against the Secretary from the Supreme Court for delivery of warrants. At that time, such an action was considered as an attempt to intrude and intermeddle with the prerogatives of the executive. Chief Justice Marshall, nevertheless, held that the Act establishing the judicial courts of the United States conferring authority on the Supreme Court to issue writ of mandamus, inter alia, to public officers in its original jurisdiction which was not warranted under the Constitution, was void. Thereafter, the principle of judicial review was firmly established in the American jurisprudence. President Charles Evan Hughes in his speech aptly remarked, "We are under a Constitution but the Constitution is what the Judges say it is." The principle of judicial review became an essential feature of written Constitutions of many countries.
Judicial review is a great weapon in the hands of judges. It comprises the power of a court to hold unconstitutional and unenforceable any law or order based upon such law or any other action by a public authority which is inconsistent or in conflict with the basic law of the land.
Broadly speaking, judicial review in India deals with three aspects:
(i)         judicial review of legislative action;
(ii)        judicial review of judicial decision; and
(iii)       judicial review of administrative action.
It is necessary to distinguish between ‘judicial review’ and ‘judicial control’. The term judicial review has a restrictive connotation as compared to the term judicial control. Judicial review is ‘supervisory’, rather than ‘corrective’, in nature. Judicial review is denoted by the writ system which functions in India under Arts. 32 and 226 of the Constitution. Judicial control, on the other hand, is a broader term. It denotes a much broader concept and includes judicial review within itself. Judicial control comprises of all methods through which a person can seek relief against the Administration through the medium of the courts, such as, appeal, writs, declaration, injunction, damages statutory remedies against the Administration.
The principle of judicial review has been held to be a basic feature of our Constitution. It is incorporated in Articles 226 and 227 of the Constitution insofar as the High Courts are concerned. Supreme Court Articles 32 and 136 of the Constitution embody the principle of judicial review. Article 32 is included in Part III as a fundamental right for enforcement of any of the fundamental rights conferred under Part III.
Under our Constitution, judicial review can conveniently be classified under three heads:
(1) Judicial review of constitutional amendments
This has been the subject-matter of consideration in various cases by the Supreme Court; of them worth mentioning are: Shankari Prasad case[v], Sajjan Singh case[vi], Golak Nath case[vii], Kesavananda Bharati case[viii], Minerva Mills case[ix], Sanjeev Coke case[x] and Indira Gandhi case[xi]; the test of validity of constitutional amendments is conforming to the basic features of the Constitution.
(2) Judicial review of legislation of Parliament, State Legislatures as well as subordinate legislation
Judicial review in this category is in respect of legislative competence and violation of fundamental rights or any other constitutional or legislative limitations;
(3) Judicial review of administrative action action of the Union of India as well as the State Governments and authorities falling within the meaning of State
Judicial review of administrative action may relate to either a non-statutory administrative action or a statutory administrative action. In both these cases violation of constitutional provisions like Articles 14, 19, 29, 30, 301, 304 etc., or any statutory provision will invalidate the administrative decision. We may in this connection be benefited by judgments of our Supreme Court in Ajay Hasia case[xii], Royappa case[xiii] and Maneka Gandhi case[xiv]. Judicial review of administrative action, observed Lord Diplock in Council of Civil Service Union[xv]:
"... one can conveniently clarify under three heads the grounds upon which administrative action is subject to control by judicial review. The first ground I would call 'illegality', the second 'irrationality' and the third 'procedural impropriety'. That is not to say that further development on a case-by-case basis may not in course of time add further grounds." Going by this classification, insofar as the illegality is concerned, errors of law which vitiate the ultimate decision are open to judicial review.
In Pearlman v. Governors of Harrow School[xvi] Lord Denning, M.R. observed:  "no court or tribunal has any jurisdiction to make an error of law on which the decision of the case depends. If it makes such an error it goes outside its jurisdiction".

01. Public Law Explained

To simplify things, public law deals with issues that affect the general public or state - society as a whole. Some of the laws that its wide scope covers are:
Administrative law - laws that govern government agencies, like the Department of Education and the Equal Employment Opportunity Commission
Constitutional laws are laws that protect citizens' rights as afforded in the Constitution
Criminal laws are laws that relate to crime
Municipal laws are ordinances, regulations and by-laws that govern a city or town
International laws are laws that oversee relations between nations

02. Private Law Explained

Private law affects the rights and obligations of individuals, families, businesses and small groups and exists to assist citizens in disputes that involve private matters. Its scope is more specific than public law and covers:
Contract law - governs the rights and obligations of those entering into contracts
Tort law - rights, obligations and remedies provided to someone who has been wronged by another individual
Property law - governs forms of property ownership, transfer and tenant issues
Succession law - governs the transfer of an estate between parties
Family law - governs family-related and domestic-related issues
However Private Law Review in Administrative Law cannot be taken under this classification as Administrative Law itself is a branch of Public Law. Hence Public Law Review and Private Law review in Administrative Action has to be viewed in a different but limited angle.

03. Public Law Review

The Indian Constitution adopted the Judicial Review on lines of U.S. Constitution. Parliament is not supreme under the Constitution of India. Its powers are limited in a manner that the power is divided between centre and states. Moreover the Supreme Court enjoys a position which entrusts it with the power of reviewing the legislative enactments both of Parliament and the State Legislatures. This grants the court a powerful instrument of judicial review under the constitution.
Both the political theory and text of the Constitution has granted the judiciary the power of judicial review of legislation. The Constitutional Provisions which guarantee judicial review of legisla­tion are Articles 13, 32, 131-136, 143, 145, 226, 227, 246, 251, 254 and 372.
Article 13 declares that any law which contravenes any of the provisions of the part of Funda­mental Rights shall be void. Articles 32 and 226 entrusts the roles of the protector and guarantor of fundamental rights to the Supreme and High Courts. Articles 131-136 entrusts the court with the power to adjudicate disputes between individuals, between individuals and the state, between the states and the union; but the court may be required to interpret the provisions of the constitution and the interpretation given by the Supreme Court becomes the law honoured by all courts of the land. Article 227 confers certain powers on the High Courts. Article 251 and 254 states that in case of inconsistency between union and state laws, the state law shall be void. Article 246 (3) ensures the state legislature’s exclusive powers on matters pertaining to the State List. Article 245 states that the powers of both Parliament and State legislatures are subject to the provisions of the constitution. Article 372 (1) establishes the judicial review of the pre-constitution legislation.
The legitimacy of any legislation can be challenged in the court of law on the grounds that the legislature is not competent enough to pass a law on that particular subject matter; the law is repug­nant to the provisions of the constitutions; or the law infringes one of the fundamental rights.
There is no express provision in our constitution empowering the courts to invalidate laws, but the constitution has imposed definite limitations upon each of the organs, the transgression of which would make the law void. The court is entrusted with the task of deciding whether any of the consti­tutional limitations has been transgressed or not.
The object of the judicial review is to demarcate the boundaries of power of Parliament, the State Legislatures and the executive actions of the Union and the States under law and also to ensure observance of procedural safeguards. It is not exercised to scuttle the authority of the legislature in the larger sense (which includes Parliament) or the executive. The courts interpret the Constitution, relevant statutes, rules or bye-laws, define the scope of power thereunder and determine whether the impugned action is intra vires or ultra vires the authority and examine as to how the power has been exercised. In exercise of judicial review of administrative action there can be no doubt that the executive power of the Union of India under Article 73 of the Constitution extends to all matters which are within its legislative competence (List I and List III of the Seventh Schedule); so also the executive power of the State under Article 162 of the Constitution extends to all matters in respect of which it is competent to legislate (List II and List III of the Seventh Schedule of the Constitution).
The power of judicial review is available to the superior courts in respect of matters falling within the realm of public law and not in respect of matters of private law. What matters fall within the purview of public law and what matters fall within the purview of private law is a moot question which needs to be debated in the seminar.

04. Private Law Review

The action of awarding contract by a public authority falls within the purview of public law but the terms of contract regarding rates, time specified for completion of work and other similar condition in the contract between public authority and the private individual as also the quantum of damages for breach of the contract, all fall within the purview of private law in respect of which no judicial review will be permissible.
Thus, grant of licences, imposition of fees, classification of land, rules relating to dealership of essential commodities, etc. which fall within the domain of public law, can be the subject-matter of judicial review. Judicial review should not be mistaken for the appeal. The right of appeal is a statutory right which can be invoked when it is so provided in the relevant Act whereas the right to seek judicial review is available even when there is a finality clause or ouster clause in an Act that the order passed by an authority thereunder is final and shall not be questioned in a court of law or that the civil court has no jurisdiction to entertain a suit in respect of any matter required to be dealt with by the authority under the Act. In the face of such a provision in any Act, an ordinary civil court has no jurisdiction to entertain a suit for adjudication of any question arising under such an Act but the extraordinary jurisdiction of the High Courts and the Supreme Court, conferred by the Constitution, is not barred. Chandra Kumar case[xvii] is a glaring example.
One important aspect to be borne in mind is that in judicial review the courts are mainly concerned with the competence of the authority and the mode in which the authority takes the decision and not the decision taken by the authority. They are not concerned with the merits of the decision. The courts do not substitute their opinion or decision in place of the impugned decision of the authority but in appeal the appellate court does have the power to consider the merits of the case and substitute its own decision for that of the subordinate court or tribunal. It is profitable to be apprised of the words of Lord Hailsham L.C., in the case of Chief Constable of N.W.[xviii]:
"Judicial review is concerned not with decision but with decision-making process. Unless that restriction on the power of court is observed, the court will under the guise of preventing the abuse of power, be itself guilty of usurping power."
STATUTORY JUDICIAL REMEDIES
Apart from the Constitutional remedies contained in Arts. 32, 136, 226 and 227, which have already been discussed in the last few chapters, certain statutes also provide for seeking remedies through the Courts by aggrieved persons against the administration. These statutory judicial remedies are of two types:
(i) general statutory remedies;
(ii) specific statutory remedies provided by specific statutes for agitating questions thereunder.
The latter may take several forms. The purpose of this chapter is to discuss some of these statutory judicial remedies available against administrative bodies.
GENERAL STATUTORY REMEDIES
The classical remedy which a person has to vindicate his legal right against an administrative authority is by way of filing a civil suit in a Court claiming the proper relief. Although with the institution of the writ system by the Constitution, the importance of this remedy has been devalued, yet it has not lost all its significance, and may have to be taken recourse to by a person affected by an administrative action if desires a relief which he may not possibly get by invoking the writ jurisdiction. For example, a writ is not available to enforce payment of money or a claim for damages accruing from a civil liability and such a matter is better determined through a civil suit may also be preferable to a writ petition when determination of a claim against the administration involves decision on questions of fact on the basis of evidence produced by the parties. The High Courts are extremely reluctant to undertake such a task in writ proceedings and hence a suit may have to be filed in such a situation.

04. Judicial Review in Administrative Action

Up to the 19th century the functions of the State in England were confined to (i) defence of the country from foreign invasion, and (ii) maintenance of law and order within the country.
Feudal, agricultural society, was relatively simple and social relations were uncomplicated. There were few laws, mainly customary (not statutory). But with the advent of industrial revolution in the 18th and 19th centuries, society became complex. Concentration of people in urban areas called for new regulatory State authorities for town planning, housing improvement, public health, education, factory management, street lighting, sewerage, drainage, sanitation, schemes for providing water, electricity, etc. Also the early 20th century laid the foundation for a Welfare State dealing with health insurance, unemployment allowance, sickness and old age benefits, free and compulsory education, etc.
This vast expansion in the State functions called for a huge amount of legislation and also for wide delegation of State functions by Parliament to executive authorities, so also was there a need to create a body of legal principles to control and to check misuse of these new powers conferred on the State authorities in this new situation in the public interest. Thus, emerged administrative law. Maitland pointed out in his Constitutional History:
"Year by year the subordinate Government of England is becoming more and more important. We are becoming a much governed nation, governed by all manner of councils and boards and officers, central and local, high and low, exercising the powers which have been committed to them by modern statutes."
But in the early 20th century following the tradition of Dicey's classic exposition in his The Law of the Constitution, there was a spate of attacks on parliamentary delegation culminating in the book New Despotism by the then Chief Justice of England, Lord Hewart published in 1929. In response, the British Government in 1932 set up a committee called the Committee on Ministerial Powers headed by Lord Donoughmore, to examine these complaints and criticisms. However, the Donoughmore Committee rejected the argument of Lord Hewart and accepted the reality that a modern State cannot function without delegation of vast powers to the executive authorities, though there must be some control on them.
Parliament could theoretically exercise this control, but in practice it could not, since it did not have the time. Hence it became the duty of the Judges, though unelected, to become representatives of the people and ensure that executive authorities do not abuse their powers, but instead use it in the public interest.
But Judges too are not supposed to act arbitrarily. Hence a body of legal principles was created (largely by Judges themselves in their judgments and not by Parliament) on the basis of which Judges had to exercise their powers of judicial review of administrative action on settled principles but not arbitrarily. It is this body of rules which is known as administrative law.
Being largely Judge-made, administrative law is not contained in any Administrative Law Act, just as the income tax law is contained in the Income Tax Act or the sales tax law in the Sales Tax Act. Hence some writers have criticized administrative law as a "wilderness of single instances, and not a separate, coherent branch of law". However, the fundamental principle behind administrative law has always remained the same, namely, that in a democracy the people are supreme, and hence all State authority must be exercised in the public interest.
It is a mistake to think that administrative law is necessarily antagonistic to efficient government. As Wade points out "intensive administration will be more tolerable to the citizen, and the Government's path will be smoother, where the law can enforce high standards of legality, reasonableness and fairness".
As pointed out by Sir John Donaldson, M.R., in R. v. Lancashire CC, ex p Huddleston[xix] the development of administrative law
"has created a new relationship between the courts and those who derive their authority from the public law, one of partnership based on a common aim, namely, the maintenance of the highest standards of public administration".
In Tata Cellular v. Union of India[xx] (para 113) the Supreme Court laid down the following basic principles relating to administrative law: (SCC pp. 687-88, para 94)
(1) The modem trend points to judicial restraint in administrative action.
(2) The court does not sit as a court of appeal but merely reviews the manner in which the decision was made.
(3) The court does not have the expertise to correct the administrative decision. If a review of the administrative decision is permitted it will be substituting its own decision, without the necessary expertise which itself may be fallible.
(4) The terms of the invitation to tender cannot be open to judicial scrutiny because the invitation to tender is in the realm of contract.  Normally speaking, the decision to accept the tender or award the contract is reached by process of negotiations through several tiers. More often than not, such decisions are made qualitatively by experts.
(5) The Government must have freedom of contract. In other words, a fair play in the joints is a necessary concomitant for an administrative body functioning in an administrative sphere or quasi-administrative sphere. However, the decision must not only be tested by the application of Wednesbury principle of reasonableness (including its other facts pointed out above) but must be free from arbitrariness not affected by bias or actuated by mala fides.
(6) Quashing decisions may impose heavy administrative burden on the administration and lead to increased and unbudgeted expenditure.
There are two kinds of controls on executive powers viz.:
(1) statutory, and
(2) non-statutory.
Statutory controls
Statutory controls are given in the statute (or rules or regulations made under the statute). Any executive action in violation of the same will be declared illegal by the courts, by applying the ultra vires doctrine.
Thus, where the London County Council had statutory powers to purchase and operate tramways, it was held by the House of Lords that it had no power to run omnibuses, which was not incidental to the running of tramways[xxi] Similarly a local authority with the power to acquire land other than "park, garden or pleasure house" acts in excess of jurisdiction in acquiring land which is part of a park.[xxii]
An executive authority may also act unlawfully if it fails to perform a duty imposed upon it by statute such as maintenance of civic services (e.g. sewerage, drainage, water supply, etc.) by the Municipalities or other local bodies whose duty under the statute is to maintain such services. Here also a mandamus will issue from the courts to compel such authority to perform its statutory duty.
Where the statute delegates a power to a particular authority, that authority cannot sub-delegate that power to another authority or person unless the statute permits such sub-delegation. Similarly, discretion exercised by the prescribed authority on the direction of a higher authority would be illegal.[xxiii]
When the statute prescribes the manner of doing an act, the authority must do it in that manner alone.[xxiv]
Difficulty, however, arises in the matter of what is called "subjective discretion" conferred by the statute. An instance of such subjective discretion is where the statute says that an executive authority can take such decision "as it deems fit". Another example is where the statute says that action can be taken or order passed where the authority has "reasonable grounds to believe" to take that action or pass such order e.g. Section 132 of the Income Tax Act which confers power on the Commissioner of Income Tax to order search and seizure where he has "reason to believe" that some person is concealing his income.
In Liversidge v. Anderson[xxv] the Defence (General) Regulations, 1939 provided: "If the Secretary of State has reasonable cause to believe any person to be of hostile origin or association he may make an order against that person directing that he be detained."
The detenu Liversidge challenged the detention order passed against him by the Secretary of State. The majority of the House of Lords, except Lord Atkin, held that the Court could not interfere because the Secretary of State had mentioned in his order that he had reasonable cause to believe that Liversidge was a person of hostile origin or association. Liversidge was delivered during the Second World War when the executive authority had unbridled powers to detain a person without even disclosing to the Court on what basis the Secretary had reached to his belief. However, subsequently, the British courts accepted Lord Atkin's dissenting view that there must be some relevant material on the basis of which the satisfaction of the Secretary of State could be formed. Also, the discretion must be exercised keeping in view the purpose for which it was conferred and the object sought to be achieved, and must be exercised within the four corners of the statute.[xxvi] Sometimes a power is coupled with a duty. Thus, a limited judicial review against administrative action is always available to the courts.
Non-statutory controls
Some of the non-statutory controls are:
(a) The Wednesbury principle
(b) Rules of natural justice
(c) Proportionality[xxvii]
(d) Promissory estoppel[xxviii]
(e) Legitimate expectation[xxix]
We may only consider some of these in detail.
Wednesbury Principle
Up to 1947 the law in England was that the courts could interfere only with judicial or quasi-judicial decisions and not with administrative decisions. This legal position changed after the famous decision of Lord Greene in Associated Provincial Picture Houses Ltd. v. Wednesbury Corpn[xxx] in which it was said:
“A person entrusted with discretion must, so to speak, direct himself properly in law. He must call his attention to matters which he is bound to consider. He must exclude from his consideration matters which are irrelevant to what he has to consider. If he does not obey those rules he may truly be said to be acting unreasonably. Similarly, there may be something so absurd that no sensible person could ever dream that it lay within the powers of the authority.” The above observation incorporates what is frequently called as the Wednesbury principle. The courts often intervene to quash as illegal the exercise of administrative discretion on the ground that it suffers from "Wednesbury unreasonableness".
Thus, in Dy. Director of Consolidation v. Deen Bandhu Rai[xxxi], the settlement officer rejected an application for permission to effect an exchange of holdings on the grounds (i) that the granting of the permission would entail considerable work on the part of officers of the department, and (ii) that the applicants were big landholders. The Supreme Court held that these reasons were not germane and pertinent for the rejection of the petitions.
In Barium Chemicals Ltd. v. Company Law Board[xxxii] the Secretary of the Company Law Board issued an order under Section 237(b) of the Companies Act, 1956 appointing inspectors to investigate the affairs of a company. Section 237(b) of the Act authorized such an appointment to investigate the affairs of a company "if, in the opinion of the Central Government" there were circumstances suggesting
(a) that the business of the company was being conducted with the intent to defraud its creditors, members, or any other person;
(b) that the persons concerned in the formation of the company or the management of its affairs had been guilty of fraud or misconduct towards the company or towards any of its members;
(c) that the members of the company had not given out all the information with respect to its affairs. The Supreme Court held that before the discretion conferred by Section 237(b) of the Companies Act can be exercised, there must exist circumstances which in the opinion of the authority suggest the grounds set out in the statute.
Unfettered discretion would also be inconsistent with Article 19 of the Constitution which permits only reasonable restrictions on the rights conferred by that Article. Similarly, it would also be violative of Article 14 which prohibits arbitrariness.[xxxiii] In Shalini Soni v. Union of India[xxxiv] the Supreme Court observed: (SCC p. 549, para 7)
"It is an unwritten rule of the law, constitutional and administrative, that whenever a decision-making function is entrusted to the subjective satisfaction of a statutory functionary, there is an implicit obligation to apply his mind to pertinent and proximate matters only, eschewing the irrelevant and the remote."
In Rohtas Industries v. S.D. Agarwal[xxxv], an investigation into the affairs of a company was ordered under Section 237 of the Companies Act, 1956. The Company Law Board took into account the fact that there were complaints of misconduct against one of the leading directors of the company in relation to other companies subject to his control for which he was being prosecuted. The Court held that this factor was irrelevant in establishing fraud.
The Wednesbury principle is often misunderstood to mean that any administrative decision which is regarded by the Court to be unreasonable must be struck down. The correct understanding of the Wednesbury principle is that a decision will be said to be unreasonable in the Wednesbury sense if (i) it is based on wholly irrelevant material or wholly irrelevant consideration, (ii) it has ignored a very relevant material which it should have taken into consideration, or (iii) it is so absurd that no sensible person could ever have reached to it.
As observed by Lord Diplock in Council of Civil Service Unions v. Minister for the Civil Service[xxxvi], a decision will be said to suffer from Wednesbury unreasonableness if it is "so outrageous in its defiance of logic or of accepted moral standards that no sensible person who had applied his mind to the question to be decided could have arrived at it."
An administrative decision cannot be struck down by the Judge merely because he disagrees with the administrator.[xxxvii] There may be degrees of unreasonableness, and the Wednesbury unreasonableness refers only to the extreme degree of unreasonableness which no sensible person could reach after taking into account the relevant materials or relevant considerations. Thus, in W (An infant), In Re,[xxxviii] Lord Hailsham observed:
"Two reasonable parents can perfectly reasonably come to opposite conclusions on the same set of facts without forfeiting their title to be regarded as reasonable. ... Not every reasonable exercise of judgment is right, and not every mistaken exercise of judgment is unreasonable."
Hence, the Wednesbury unreasonableness means "unreasonableness verging on absurdity" as observed by the House of Lords in R v Hillingdon LBC ex parte Puhlhofer.[xxxix]
Rules of Natural Justice
The rules of natural justice were originally only two viz.:
1. Audi alteram partem i.e. the person(s) to be affected by an order of the authority should be heard before the order is passed, and
2. The rule against bias.
Subsequently, some more rules of natural justice are in the process of development e.g. that the administrative authority should give reasons for its decisions, particularly when the decisions affect the rights and liabilities of the citizens.
It must, however, be made clear that the rules of natural justice are flexible, and are not a straitjacket formula.[xl] In exceptional cases not only can they be modified but even excluded altogether.[xli] Natural justice is not an unruly horse. If fairness is shown, there can be no complaint of breach of natural justice.[xlii]
As regards the rule audi alteram partem, up to 1964 the legal position in England was that in judicial and quasi-judicial proceedings opportunity of hearing had to be given, but it was not necessary to do so in administrative proceedings. This legal position changed in Ridge v. Baldwin[xliii] in which the House of Lords held that opportunity of hearing had to be given even in administrative proceedings if the administrative order would affect the rights and liabilities of the citizens. This view of the House of Lords was followed by the Supreme Court in State of Orissa v. Dr. Binapani Dei[xliv] and State of Maharashtra v. Jalgaon Municipal Council[xlv] wherein it was held that administrative orders which involve civil consequences have to be passed consistently with the rules of natural justice. The expression "civil consequences" means where rights and liabilities are affected. Thus, before blacklisting a person he must be given a hearing.[xlvi]
It may be noted that even if the statute does not expressly require that opportunity of hearing must be given before passing an order which affects rights and liabilities, the courts have held that such opportunity of hearing must be given unless expressly excluded by the statute.[xlvii] Thus, natural justice is an implied requirement of administrative decisions which affects rights and liabilities.
It may be mentioned that a hearing need not always be an oral hearing. In certain circumstances, the Administrator can only issue a show-cause notice to the party likely to be affected and on his/her reply can pass the decision without giving a personal hearing to the parties. However, in certain circumstances where the party may be very seriously affected the courts have insisted that an oral hearing with opportunity of presenting witnesses and cross-examining the witnesses on the other side must be given.
Similarly, the principle that "no man should be a judge in his own cause" disqualifies an Administrator from giving a decision which affects the rights and liabilities, if he is biased.
It may, however, be pointed out that in H.C. Narayanappa v. State of Mysore[xlviii] the Supreme Court observed that the Minister or officer invested with the power to hear objections to a scheme is acting in his official capacity and unless there is reliable evidence to show that he is actually biased, his decision will not be liable to be called in question merely because the objections to the government scheme are heard by the government itself or by its officers.
The requirement to give reasons in administrative decisions which affect rights and liabilities has been held to be mandatory by the Supreme Court in S.N. Mukherjee v. Union of India.[xlix] This reduces the chances of arbitrariness on the part of the authority, as the reasons recorded by him are subject to judicial scrutiny by the higher courts or authorities.
Before concluding, it must also be mentioned that there are certain administrative matters which are inappropriate for judicial review. One of these is policy decisions of the government or of the executive authority which ordinarily should not be interfered with by the courts unless they are clearly violative of the statute or shockingly arbitrary.[l] In a case, the Central Government had initially decided to locate the headquarters of South Western Railways at Bangalore. Later it was decided to locate it at Hubli, and this decision was challenged. The Supreme Court held that it was a policy decision and hence the Court cannot interfere, even if the decision was political.[li] Similarly, maintenance of law and order is an executive function, and the courts should not ordinarily interfere with the same.[lii]  Apart from that, practically every legal system recognizes certain subjects as inappropriate for judicial review e.g. foreign affairs, declaration of wars, etc.

05. Remedies in Judicial Review

01. Constitutional Remedies

Judicial control of administrative action provides a fundamental safeguard against the abuse of power. Since our Constitution was built upon the deep foundations of rule of law, the framers of the Constitution made sincere efforts to incorporate certain Articles in the Constitution to enable the courts to exercise effective control over administrative action. Let us discuss those articles of the constitution: -
(a) Under article 32, the Supreme Court has been empowered to enforce fundamental rights guaranteed under Chapter III of the Constitution. Article 32 of the Constitution provides remedies by way of writs in this country. The Supreme Court has, under Article 32(2) power to issue appropriate directions, or orders or writs, including writs in the nature of habeas corpus, certiorari, mandamus, prohibition and quo- warranto The court can issue not only a writ but can also make any order or give any direction, which it may consider appropriate in the circumstances. It cannot turn down the petition simply on the ground that the proper writ or direction has not been prayed for.
(b) Under article 226 concurrent powers have been conferred on the respective High Courts for the enforcement of fundamental rights or any other legal rights. It empowers every High Court to issue to any person or authority including any Government, in relation to which it exercises jurisdictions, directions, orders or writs including writs of habeas corpus,. mandamus, prohibition, quo warranto and certiorari.
(c) Under Article 136 the Supreme Court has been further empowered, in its discretion, to grant special leave to appeal from any judgment, decree, determination, sentence or order by any Court or tribunal in India. Article 136 conferred extraordinary powers on the Supreme Court to review all such administrative decisions, which are taken by the administrative authority in quasi-judicial capacity.
An order made by a quasi-judicial authority having jurisdiction under an Act which is intra virus is not liable to be questioned on the sole ground that the provisions of the Act on the terms of the notification issued there under have been misinterpreted. The rule of maintainability of petition under Article 32 held above is subject to three exceptions.
First, if the statute for a provision thereof ultra vires any action taken there under by a quasi-judicial authority which infringes or threatens to infringe a fundamental right, will give rise to the question of enforcement of that right and petition under Article 32 will lie.
Second, if a quasi-judicial authority acts without jurisdiction or wrongly assumes jurisdiction by committing error as to a right, the question of enforcement of that arises and a petition under Article 32 will lie even if the statute is intra vires.
Third, if the action taken by a quasi-judicial authority is procedurally ultra virus, a petition under Article 32 would be competent.
Remedy through Special Leave to appeal under article 136. Articles 132 to 135 of the Constitution deal with ordinary appeals to the Supreme Court in constitutional, civil and criminal matters. Article 136 deals with a very special appellate jurisdiction conferred on the Supreme Court. Under this provision the Supreme Court has power to grant in the discretion, special leave to appeal from
(a) Any judgment, decree, determination or order;
(b) In any cause or matter;
(c) An order passed or made by any court or tribunal in the territory of India.
Remedies for enforcing administrative law are available before the higher judiciary e.g. the Supreme Court under Article 32 of the Constitution and the High Courts under Article 226 of the Constitution. The higher judiciary can issue writs of certiorari, mandamus, habeas corpus, prohibition and quo warranto and also issue orders or directions "in the nature of writs".
The language used in Articles 32 and 226 is thus wide, and it has been held that the Indian courts have wider powers than the British courts in issuing writs.[liii] Article 226 confers powers on the High Court not only to issue prerogative writs, but also issue order or direction to enforce fundamental and other legal rights.[liv] Hence the High Courts in India are not confined to the procedural technicalities of the English rules.[lv] The Court can also mould the relief to meet the peculiar and complicated requirements of this country, provided the High Court does not contravene any provisions of the Constitution or the law.
A writ can be issued by the High Courts and the Supreme Court not only to the Government, but also to what are called instrumentalities of the State. A writ of certiorari will be issued when the court finds that there is an error of law apparent on the face of record. A mandamus will be issued to a public authority to compel it to do its public duty.
In the grants of public contracts the courts usually (though not invariably) insist that such grants be made by public auction/public tender after advertising the same in well-known newspapers having wide circulation so that there is transparency and compliance with Article 14 of the Constitution. Such grants by private negotiation are ordinarily disapproved.[lvi]
A writ can be issued to enforce the statute or statutory rule or order. However, a question may arise whether it can be issued to enforce non-statutory government orders or executive instructions. The earlier decisions of the Supreme Court were of the view that no mandamus will issue to enforce mere administrative instructions which have no statutory force.[lvii] However, subsequently, certain exceptions have been carved out to the above principle. In certain exceptional circumstances, mandamus can be issued to enforce a non-statutory administrative order. Some of such exceptions are:
(i) Where the principle of promissory estoppel applies e.g. in Union of India v. Indo Afghan Agencies Ltd,[lviii] Motilal Padampat Sugar Mills Co. Ltd. v. State of U.P.[lix], etc.
(ii) Where the principle of legitimate expectation applies.[lx]
(iii) In service matters, where there are no statutory rules, administrative instructions can fill in the gap, and are enforceable.[lxi]
(iv) In many matters e.g. awards of public contracts, an executive authority must be rigorously held to the standards by which it professes its actions to be judged, even if such actions are non-statutory.[lxii]

02. Statutory Review

The method of statutory review can be divided into two parts:
i) Statutory appeals
There are some Acts, which provide for an appeal from statutory tribunal to the High Court on point of law. e.g. Section 30 Workmen’s Compensation Act, 1923.
ii) Reference to the High Court or statement of case
There are several statutes, which provide for a reference or statement of case by an administrative tribunal to the High Court. Under Section 256 of the Income-tax Act of 1961 where an application is made to the Tribunal by the assessee and the Tribunal refuses to state the case the assessee may apply to the High Court and if the High Court is not satisfied about the correctness of the decision of the Tribunal, it can required to Tribunal to state the case and refer it to the Court.)

03. Ordinary Remedies or Equitable Remedies

Meaning of Equity
Before we discuss equitable remedies, it is necessary for us to know something about equity. Since the administration of justice has begun on the basis of law in the world, a class of society has always been against the rigidity of law. This class of society is of the opinion that howsoever mature and legally skilled men may make the laws, yet they cannot experience the circumstances which the judges may have to face in future. The circumstances in which the provisions of law may prove to be unjust for the people if is necessary to make the provisions of law flexible, and injustice caused by such rigidity of law should be stopped. Equity is based on this consideration. Equity is a voice against injustice caused by rigidity of low. Equity, which is not a synonym of natural justice, demands that justice should be made in accordance with the circumstances. Equities a new and independent system of law which developed in England. It has its own history and origin. It made an important contribution in the English system of law as a supplementary of main legal system till 1873, when it was merged in the common law According to Ashburner. “Equity is a word which has been borrowed by law from morality and which was acquired in law a strictly technical meaning.”
Apart from the extra-ordinary (Constitutional Remedies) guaranteed as discuss above there are certain ordinary remedies, which are available to person under specific statutes against the administration. The ordinary courts in exercise of the power provide the ordinary remedies under the ordinary law against the administrative authorities. These remedies are also called equitable remedies. This includes:
 i) Injunction
ii) Declaratory Action
iii) Action for damages.
In some cases where wrong has been done to a person by an administrative act, declaratory judgments and injunction may be appropriate remedies. An action for declaration lies where a jurisdiction has been wrongly exercised. Or where the authority itself was not properly constituted. Injunction s issued for restraining a person to act contrary to law or in excess of its statutory powers. An injunction can be issued to both administrative and quasi-judicial bodies. Injunction is highly useful remedy to prevent a statutory body from doing an ultra vires act, apart from the cases where it is available against private individuals e.g. to restrain the commission or torts, or breach of contract or breach of statutory duty.
Before discussing these remedies let us find out what is the meaning of equity.

04. Injunction

An injunction is a preventive remedy. It is a judicial process by which one who has invaded or is threatening to invade the rights of another is restrained from continuing or commencing such wrongful Act. In India, the law with regard to injunctions has been laid down in the Specific Relief Act, 1963. Injunction may be prohibitory or mandatory.
Prohibitory Injunction
Prohibitory injunction forbids the defendant to do a wrongful act, which would infringe the right of the plaintiff. A prohibitory injunction may be interlocutory or temporary injunction or perpetual injunction.
Interlocutory or temporary injunction
Temporary injunctions are such as to continue until a specified time or until the further order of the court. (S. 37 for the specific Relief Act). It is granted as an interim measure to preserve status quo until the case is heard and decided. Temporary injunction may be granted at any stage of a suit. Temporary injunctions are regulated by the Civil Procedure Code. Temporary injunction is provisional in nature. It does not conclude or determine a right. Besides, a temporary injunction is a mere order. The granting of temporary injunction is a matter of discretion of the court.
Perpetual injunction
A perpetual injunction is granted at the conclusion of the proceedings and is definitive of the rights of the parties, but it need not be expressed to have perpetual effect, it may be awarded for a fixed period or for a flexed period with leave to apply for an extension or for an indefinite period terminable when conditions imposed on the defendant have been complied with; or its operation may be suspended from a period during which the defendant is given the opportunity to comply with the conditions imposed on him, the plaintiff being given leave to reply at the end of that time.
Mandatory injunction
When to present the breach of an obligation, it is necessary to compel the performance of certain acts which the court in capable of enforcing, the court may in the discretion grant an injunction to prevent the breach complained of an also to compel performance of the requisite acts. (S. 39 of the Specific Relief Act.) The mandatory injunction may be taken as a command to do a particular act to restore things to their former condition or to undo, that which has been done. It prohibits the defendant from continuing with a wrongful act and also imposes duty on him to do a positive act. For example construction of the building of the dependent obstructs the light for which the plaintiff is legally entitled. The plaintiff may obtain injunction not only for restraining the defendant from the construction of the building but also to pull down so much of the part of the building, which obstructs the light of the plaintiff.

05. Declaration (Declaratory Action)

Declaration may be taken as a judicial order issued by the court declaring rights of the parties without giving any further relief. Thus a declaratory decree declares the rights of the parties. In such a decree there is no sanction, which an ordinary judgment prescribes same sanctions against the defendant. By declaring the rights of the parties it removes the existing doubts about the rights and secures enjoyment of the property. It is an equitable remedy. Its purpose is to avoid future litigation by removing the existing doubts with regard to the rights of the parties. It is a discretionary remedy and cannot be claimed as a matter of right.

06. Action for Damages

If any injury is caused to an individual by wrongful or negligent acts of the Government servant the aggrieved person can file suit for the recovery of damages from the Government concerned. This aspect of law has been discussed in detail under the topic liability of Government or state in torts.

07. Other Remedies

There are some other remedies available for private law reviews by subordinate Courts.

03. SCOPE, EXTENT AND TYPES OF PRIVATE LAW REVIEW IN ADMINISTRATIVE ACTION

01. Scope and Extent of Private Law Review

The general rule of law is that when an infringement of a legal right is alleged, a cause of action arises, and unless there is a bar to the entertainment of the suit, the ordinary civil courts are bound to entertain the claim. To enable a person to file a civil suit s. 9 of the Code of Civil Procedure provides that the Courts shall have jurisdiction to try "all suits of civil nature excepting suits of which their cognizance is either expressly or impliedly barred." This provision confers jurisdiction on civil courts to hear and decide all disputes of a civil nature. But this is circumscribed by the rider that a suit barred expressly or implicitly may not lie. A suit may be barred impliedly or expressly by a statute against administrative authority. Further suits against the Government for damages arising out of a tort or breach of a contract though could be filed under s. 9, C.P.C., are subject to a few constitutional restrictions and this matter is again examined in the next two chapters. If there is no implied or express bar, a civil suit can be filed against an administrative authority and proper relief sought against it. For example, a suit may be filed for refund of tax which has been paid under a law, which is later declared unconstitutional and the plaintiff has not passed on the burden of tax to others.[lxiii]
In many situations involving wrongs done to persons by administrative authorities, damages may not be an appropriate remedy, or the person concerned may be more interested in making the administration comply with the law in question so that either it desists from taking, an action which may be injurious to the person concerned, or it rights a wrong done to him. Suits for injunctions and declarations under the Specific Relief Act, 1963 are the remedies appropriate to achieve the desired ends. These remedies have been considered below.
The remedies mentioned here, viz.; a civil suit to claim damages, or a suit for an injunction or a declaration, are essentially private law remedies which have been pressed into service in the area of public law as well.

02. Types of Private Law Review

Private Law Review as we have already seen, covers all judicial reviews except Public Law Reviews whose remedies are mostly by way of writs. The remedies of Private Law Reviews are ordinary or equitable remedies. They may be classified as:
01. Injunctions
02. Declarations
03. Action for Damages
04. Other Remedies

04. INJUNCTIONS

01. Injunction in General

An injunction is an order made by the court to stop a public body from acting in an unlawful way. Less commonly, an injunction can be mandatory, that is, it compels a public body to do something. Where there is an imminent risk of damage or loss, and other remedies would not be sufficient, the court may grant an interim injunction to protect the position of the parties before going to a full hearing. If an interim in injunction is granted pending final hearing, it is possible that the side which benefits from the injunction will be asked to give an undertaking that if the other side is successful at the final hearing, the party which had the benefit of the interim protection can compensate the other party for its losses. This does not happen where the claimant is legally aided. An injunction can be temporary or permanent, prohibitory or mandatory.
Through an injunction, a public authority may be commanded to do a thing which the law requires it to do, or to refrain from doing something which is illegal. An injunction can be issued to an administrative or a quasi-judicial body. An injunction is primarily private law remedy, but is used in the area of public law as well to prevent the administration from breaking the law.
Before the Constitution came into operation, under s. 45 of the Specific Relief Act, 1877, each of the three High Courts of Bombay, Calcutta, and Madras could issue orders, in the nature of mandamus, to public authorities, that is, they could "make an order requiring any specific act to be done or forborne" by a public authority within the local limits of its ordinary original civil jurisdiction. Under this provision, the order could be issued only to such authorities as were located within the three Presidency Towns and not in the mofussil. No other Court could issue such an order.
There was a historical reason for the three High Courts to enjoy such a power. The three High Courts enjoyed the power to issue the writ of mandamus as inheritors of the jurisdiction or their predecessors, the Supreme Courts, established earlier.  The Supreme Courts had the same jurisdiction and authority as the judges of the Court of King's Bench in England. As the three High Courts had absorbed into themselves the Supreme Courts, they secured their powers and became entitled to issue the writ within the same territorial ambit as the Supreme Courts had been entitled to. S. 45 of the Specific Relief Act, 1877 gave statutory recognition to this position by conferring power on them to issue mandatory injunctions against public authorities. The same Act through s. 50 enjoined upon all the High Courts not to issue the writ of mandamus.
After the Constitution came into operation, it became redundant to retain the peculiar position of the three High Courts as Art. 226 of the Constitution conferred power on all the High Courts in India to issue writs. In fact, the Adaptation of Laws Order, 1950 provided in s. 50 of the Specific Relief Act of 1877 that "Nothing in the Chapter shall affect the power conferred on a High Court by clause (1) of article 226 of the Constitution." The Law Commission of India recommended the abolition of s. 45 of the Act as it had become nugatory after the Constitution.[lxiv] Consequently, s. 45 was dropped when the Specific Relief Act of 1963 was enacted. Apart from s. 45, sections 54 and 55 of the Specific Relief Act, 1877 conferred a general power on the courts to issue perpetual and mandatory injunctions respectively. Under sections 54 and 55, a suit for the grant of injunction normally had to be filed in the lower court from whose decision appeal could be preferred to the High Court by the dissatisfied party. Sections 45 and 55 were regarded as being independent of each other and all the High Courts could issue mandatory injunctions under section 55. The remedy provided in section 45 was held to be in the nature of a summary remedy, which in no way interfered with regular suits.[lxv]
At present, the law relating to injunctions is laid down in the Specific Relief Act, 1963 which has repealed the corresponding Act of 1877. Injunctions are classified into three categories; temporary, perpetual, and mandatory. Temporary and perpetual Injunctions are preventive in character. According to s. 36, preventive relief is granted, at the discretion of the Court, by injunctions - temporary or perpetual. According to s. 37(1), a temporary injunction is to continue until a specified time, or until further order of the Court; it may be granted at any stage of a suit, and is regulated by the Code of Civil Procedure. Rules 1 and 2 of Order 39 of the C.P.C., deal with temporary injunctions. Such an injunction is grantable at the instance of the plaintiff at the discretion of the court if it is proved to its satisfaction that unless the defendant is immediately restrained by an injunction, irreparable loss or damage will be caused to the plaintiff during the pendency of the suit. The purpose of a temporary Injunction is, thus, to maintain the status quo pending, hearing and disposal of the suit on merits till further orders are made by the court. A court grants an interim injunction if three conditions are satisfied: (i) making out a prima facie case; (ii) showing that the balance of convenience is in the applicant's favour in that the refusal of the injunction would cause greater inconvenience to him; and (iii) whether on refusal of the injunction he would suffer irreparable loss. In Chandulal v Delhi Municipal Corporation[lxvi] the court refused to grant an interim injunction against the Corporation in a matter of cancellation of the plaintiff's licence to use a kiosk. The Court pointed out that such an injunction can be granted only if the plaintiff shows that he has a legal right which has been infringed. Granting of an injunction is a matter of discretion with the Court and in its exercise the Court has to satisfy itself whether the plaintiff has a triable case. While seeking an interim injunction, plaintiff has to disclose existence of a prima facie case. Prima facie case is not to be confused with prima facie title. Non grant of injunction must result in irreparable injury to the party seeking relief. The balance of convenience must be in favour of grant of injunction. As a principle ex parte injunction would be granted under exceptional circumstances.[lxvii] While dealing with a prayer of temporary injunction, the court is not to deal the case as if it is deciding the case finally. The existence of a prima facie case is enough.[lxviii] The purpose of grant of temporary injunction is to lessen the risk of irreparable injury and injustice, which cannot be compensated in terms of money, which would result from the violation by the defendant of some right of the plaintiff.[lxix]
The object of grant of injunction is to prevent the threatened injury or breach of the right.[lxx] In Dorab Cawasji's case, the Supreme Court laid down the criterion in cases wherein an ex parte injunction can be granted.[lxxi] The aforesaid principle was approved in Matro Martins case.[lxxii] The court should not grant the relief of mandatory injunction in temporary form without assigning any special reason or without recording a finding that a prima facie case is made out. Interlocutory injunction being an equitable relief is in the discretion of the court. The conduct of the party seeking the injunction has to be fair.[lxxiii]
When the balance of convenience lies in favour of the defendant, an interim injunction cannot be granted in favour of the plaintiff on the ground that there is a prima facie case in his favour. The principle of balance of convenience cannot be ignored in such a case.[lxxiv]
The court has no jurisdiction under section 41(b) of the Specific Relief Act. 1963 or under its inherent jurisdiction, under its inherent powers or under section 151 of the Code of Civil Procedure, 1908 to grant temporary injunction restraining a person from instituting any proceedings which such person is entitled to institute.[lxxv]
A perpetual injunction can be granted, under s. 37(2), by a decree made after the hearing and upon the merits of the suit. According to s. 38(1), it may be granted to the plaintiff to prevent the breach of an obligation existing in his favour whether expressly or by implication. Through a perpetual injunction, the defendant is perpetually enjoined from assertion of a right, or from the commission of an act, which would be contrary to the rights of the plaintiff. Ordinarily, an injunction is not issued to prevent breach of a contract because a contract is usually not specifically enforceable and damages may be a sufficient recompense for breach of a contract. If, however, there exists no standard to ascertain damages caused by the non-performance of a contract, or where the act agreed to be done is such that compensation in money for its non-performance would not afford adequate relief an injunction may be granted to prevent its breach.[lxxvi] When the defendant invades or threatens to invade the plaintiff's right to, or enjoyment of, property, the court may grant a perpetual injunction, inter alia, where there exists no standard for ascertaining the actual damage caused, or likely to be caused, by the invasion, or where the invasion is such that compensation in money would not afford adequate relief, or where the injunction is necessary to prevent multiplicity of judicial proceedings.
A mandatory injunction not only involves prohibition but also imposes a positive duty on the defendant to do something. According to s. 39, when to prevent the breach of an obligation, it is necessary to compel the performance of certain acts which the court is capable of enforcing. The Court may, in its discretion, grant an injunction to prevent the breach complained of, and also to compel performance of the requisite acts. Under s. 40, the plaintiff in a suit for perpetual or mandatory injunction can also claim damages either in addition to, or in substitution of, such injunction. The Court may, in its discretion, award damages.
An injunction is pre-eminently a discretionary remedy, but the Court has to exercise its discretion judicially. Since injunction is an equitable remedy, it may be refused, inter alia, when the conduct of the plaintiff is such as to disentitle him of the assistance of the Courts (S 41 (i)) or when equally efficacious relief can be obtained by any other usual mode of proceedings [s. 41(h)].[lxxvii] For instance, an injunction will not be issued when damages would be an adequate remedy to the aggrieved party,[lxxviii] as in the case of a breach of contract. As regards alternative legal remedy, it will differ from case to case whether the law provides for an equally efficacious remedy through usual mode of proceedings, and no hard and fast rule can be laid down in this regard.[lxxix] The stress is upon the words "equally efficacious" and "usual mode of proceedings.” In Montogemery Municipality V. Sant Singh[lxxx], the Municipal Committee imposed a tax on a person, on whom it could not be imposed under the Municipal Act, and committed a breach of obligation, implicitly existing in his favour. It was held that the person aggrieved could relieve himself from harassment by invoking the relief of injunction, as there was no "other usual mode of proceeding" available to him which could be considered to be "equally efficacious." Where a Municipal Committee issued a notice to a house-owner asking him to remove certain encroachments on the municipal land, a suite for injunction against the municipality would lie as there was no other efficacious remedy open to him.[lxxxi] On the whole, in practice, this provision has hardly proved to be a significant restriction on the Court's power to issue injunction.[lxxxii]
In Vaish Degree College v. Lakshmi Narain[lxxxiii], the Supreme Court emphasized that the relief of injunction is purely discretionary and the plaintiff cannot claim it as a matter of right. It is more in the nature of an equitable relief than a legal remedy. The Court grants the relief according to legal principles and ex-debito justitiae. The Court must keep in mind the principles of justice and fair play and should exercise the discretion only if the ends of justice require it. The Court refused to grant the relief to the plaintiff-teacher as it was a matter of employer-employee relationship, even though regulated by statute, and it would have caused undue hardship to the college authorities. Instead, the Court awarded some monetary compensation to the plaintiff. The result reached by the court in the instant case is not happy. It is coloured by the private law approach that a service contract is not specifically enforceable. But this approach should not apply when there is some statutory protection given to the employee or when there is an element of public employment in service contract. This approach is depicted by Sirsi Municipality v. CKF Tellis[lxxxiv] where in a suit for declaration the Court held that the order of the municipality was void when it failed to carry out its mandatory duty, embodied in a rule, in terminating the services of an employee . The reason for this was that a municipality was a statutory body and service therein had elements of public employment. Colleges are affiliated to universities which are statutory bodies: the colleges function under statutory rules made by the concerned university and security of tenure of teacher is an accepted value at the present day.
The Specific Relief Act of 1877 contained a provision [so 56(d)] laying down that an injunction could not be granted "to interfere with the public duties of any department of the Central Government or any State Government.” In actual practice, however, this hardly operated as a limitation on the Courts in the matter of issuing injunctions. The clause did not immunize ultra virus actions of the government.[lxxxv] In one case, a District Magistrate was held not to be a department of the government and, consequently, the clause did not bar issue of injunction to him.[lxxxvi] As a result of the comments of the Law Commission that such a principle "is inconsistent with the principal embodied in the second proviso to Article 361(1)" of the Constitution. Clause (1) of article 361 protects the official acts of the President and Governors. The proviso provides that "nothing in this clause shall be construed as restricting the right of any person to bring appropriate proceedings against the Government of India or the Government of a State."  This restrictive clause his now been dropped and is not to be found in the present Act.

02. Injunction compared with Mandamus

Basically, the nature of all injunctions is very much like the writ of mandamus. Both are orders passed by the Court asking an administrative authority to perform a legal duty, or to desist from doing an illegal act. Disregard of both operates as contempt of the Court. In both, the Courts would not extend their protection of there is an alternative legal remedy available to the individual.
An injunction has several advantages over mandamus. First, a suit for injunction can be filed in the district courts, whereas a petition for mandamus has to be made to the High Court. For an individual, therefore, injunction may be, as a practical matter, a less expensive remedy, and more convenient if he is located at a place away from the High Court. Secondly, while oral evidence can be taken by the courts in a suit for injunction, the High Courts in writ petitions are generally averse to investigating disputed questions of fact. The scope of judicial review is, therefore, wider in a suit for injunction. Thirdly, claims for injunction and damages may be combined in the same suit. Courts do not award damages while entertaining applications for mandamus.
In spite of these advantages of an injunction, it is not as effective and popular a remedy as mandamus. This is due to several reasons. First, mandamus is a constitutional remedy and no statute can exclude the jurisdiction of the High Courts to grant it. On the other hand, since injunction is a statutory remedy, a statute may bar the Courts from entertaining suits for injunction.[lxxxvii]
Another limitation from which the remedy by way of injunction suffers is the notice requirement prescribed by s. 80 of the Civil Procedure Code,[lxxxviii] though the rigours of this requirement have been somewhat lessened by the Code of Civil Procedure (Amendment) Act, 1976. Thirdly, injunction is a dilatory remedy as the District Courts take long in disposing of cases. A writ petition, on the other hand, is disposed of by the High Court comparatively expeditiously. This factor attracts people to resort to writs rather than to injunctions.[lxxxix]

05. DECLARATIONS

A declaration is a judgment by the Administrative Court which clarifies the respective rights and obligations of the parties to the proceedings, without actually making any order. Unlike the remedies of quashing, prohibiting and mandatory order the court is not telling the parties to do anything in a declaratory judgment. For example, if the court declared that a proposed rule by a local authority was unlawful, a declaration would resolve the legal position of the parties in the proceedings. Subsequently, if the authority were to proceed ignoring the declaration, the applicant who obtained the declaration would not have to comply with the unlawful rule and the quashing, prohibiting and mandatory orders would be available.

01. Declaratory Actions

A declaratory action or decree denotes that action of the Court wherein it declares the rights of the parties without living further relief. It differs from an ordinary judgment which can be enforced through execution proceedings. A declaratory judgment does not prescribe any sanction against the defendant. The rationale behind such a judgment is that coercion is not always necessary for obeying a verdict of a court and often the parties would obey the law without any sanction. This is particularly true of public authorities. If the existing doubt regarding the legal rights is removed, then it can be supposed that public authorities would act according to law. In fact, every decision against the government is a sort of declaration because it is up to it to obey the same or not, the judiciary possessing no physical power of its own to enforce obedience.
The purpose of declaration is to avoid future litigation by removing existing causes or controversies, e.g., where a man is in possession of some property under a title about which there is sonic legal doubt, he may obtain a declaration in his favour to clear his title. Or, to take another illustration, where there exists a dispute about the status of two persons as husband and wife and the legitimacy of the children, declaration would be an appropriate remedy to clarify the legal position. A declaratory action is particularly useful where a legal dispute exists but no positive wrong has been committed or has taken place entitling a party to claim coercive relief. As de Smith states, through declaration "inconvenience and the prolongation of uncertainty are avoided.”
It is important to remember that courts do not give advisory opinions or opinions on hypothetical questions and it is essential that some genuine dispute should exist, though no violation of the rights of either party may have taken place, before a court will give a declaratory relief. In Bai Shri Vaktuba v. Thakore[xc], the plaintiff-husband filed a suit for declaration that a two year old boy allegedly born to the defendant wife was not his son. An objection was taken that the suit was premature as no maintenance and rights in the plaintiff's estate were being claimed against the plaintiff and that the interest of the minor should not be prejudiced by deciding a question which would arise in future. The court did not accept the contention as the wife had been making an open assertion that the boy was plaintiff's son. In the opinion of the Court, the infant's case could be sufficiently placed before the Court by a duty constituted guardian. To hold otherwise would amount to holding that the plaintiff, openly threatened with this serious claim, is condemned to inactivity for, it may be 20 or 30 years, leaving it to the claimant to file his suit at such time as would most assist him taking the plaintiff at a disadvantage." Further, questions of birth and paternity should be determined while the evidence is still available.
It was in the year 1859 that the Civil Procedure Code, 1859 provided in s. 15 that no suit would be open to objection on the ground that a mere declaratory decree or order was sought thereby, and that it would be lawful for the civil courts to make binding declaration of rights without granting consequential relief. Subsequently, provision was made in s. 42 of the Specific Relief Act of 1877 for declaratory decrees and the provision in the C.P.C. was repealed. Now declaratory relief can be granted under s. 34 of the Specific Relief Act, 1963. Apart from this provision, it is usual for the courts, as seen in a previous chapter, to pass declaratory orders by which they declare an administrative action, rule or statute ultra vires without giving further relief in writ petitions under Arts. 32 and 226.

02. Declarations under Specific Relief Act etc.

S. 34 of the Specific Relief Act, 1963 provides that any person entitled to any legal character, or to any light as to any property, may institute a suit against any person, denying, or interested to deny, his title to such character or right, and the Court may in its discretion make therein a declaration that he is so entitled, and the plaintiff need not in such suit ask for any further relief. No court would, however, make any such declaration where the plaintiff, being able to seek further relief than a mere declaration of title, omits to do so. To seek a declaration, therefore, two things are essential:
(1) The plaintiff is entitled to any legal character, or any right as to any properly, and the same is being denied by any person.
(2) The plaintiff is not able to seek further relief in addition to declaration. But if he is able to seek a further relief, then the Court would not grant a mere declaration.
Under s. 35 of the Act, a declaration made by the court is binding only on the parties to the suit and persons claiming through them.
There was a conflict of judicial opinion whether the provisions made by the Specific Relief Act are exhaustive of the declaratory actions or whether a court could grant a declaration outside the Act. In some cases,[xci] the view was taken that it was not exhaustive and declarations could be granted independently of the section, but in others a contrary view was taken.[xcii] The Supreme Court in Ramaraghava Reddy v. Seshu Reddy[xciii] preferred the first view. A worshipper filed a suit for declaration that certain properties belonged to the deity. Here it is clear that the worshipper himself was not claiming any legal character or right in the property, and, therefore, the suit did not fall within the purview of s. 34. The court held that s. 34 was not exhaustive of declaratory decrees and the worshipper was entitled to maintain the suit. Such a suit lies independently of s. 34 and is governed by the general provisions of the CPC, like s. 9, or Order 7, rule 7.
"Legal character" means a position recognized by law. Legal character is synonymous with legal status,[xciv] "Legal character" in s. 34 includes the status of a person and would Cover many situations, where a legal right of a person is infringed by an illegal or ultra vires action of an administrative authority, e.g., a right to vote or stand as a candidate at a municipal election, Thus, a declaration can be sought that the plaintiff's nomination paper at a municipal election has been illegally rejected and that the defendant has not been duly elected as a member of the Municipal Committee.[xcv] Similarly, a suit lies for declaration that an order compulsorily retiring the plaintiff is illegal and ultra vires,[xcvi] Where the Board of Revenue converted, in revision, the order of suspension of the plaintiff into one of dismissal, the plaintiff could sue for a declaration that the board's order was without jurisdiction and infringed the relevant law.[xcvii] In the matter of employer-employee relationship, a court can grant a declaration in any of the three situations:
(i) where a public servant has been dismissed in contravention of the guarantee contained in Art. 311;
(ii) where a worker has been dismissed in contravention of industrial and labour law; and (iii) where a statutory body has acted in breach of a mandatory obligation imposed by a statute.[xcviii]
Further, the expression 'right as to property' is of broad significance as it does not mean a right in the property. Thus, an individual rate-payer of a municipality can maintain a suit for declaration that sale of municipal land by the municipality is in contravention of the statute.[xcix] This is on the basis that the rate-payers have a peculiar and special interest in municipal properties and are vitally concerned with illegal or ultra vires acts of the Municipal Committee.
The expression "legal character" or "right to property" does not cover merely pecuniary[c] or contractual relationship.[ci] In such a situation, a suit for debt or damages, as the case may be, will lie but not a suit for declaration. There is a difference between a declaration coupled with a claim for a specified sum as a consequential relief and a case where the sole prayer is for declaration that a certain sum belongs to the plaintiff.[cii] The former comes within the purview of the Specific Relief Act but not the latter.
The proviso to s. 34 requires that if the plaintiff can claim further relief he must do so. The object of the proviso is to prevent multiplicity of suits. The relief provided for in the section does not mean every kind of relief but one which would complete the claim of the plaintiff and not lead to multiplicity of suits. It is further relief and not other relief. The relief ought to flow necessarily from the effect of the declaration and should be available in the same proceedings. But, if the relief is remote, and not connected with the cause of action, then the plaintiff need not claim it. The relief should be appropriate to, and consequent on, the right asserted or denied.[ciii] A suit for declaration is liable to be thrown out if the consequent relief which the plaintiff can claim is not claimed though the Court may permit the plaintiff to amend the plaint.[civ] Whether the consequent relief could have been claimed or not depends upon the facts and circumstances of each case.[cv] There has been a mass of case-law, and much judicial uncertainty on this question. Here only one illustration may be taken to show the application of the principle. In the matter of wrongful dismissal from service, it has been held in several cases that the plaintiff should claim not only a declaration that his dismissal was wrongful but also the consequential relief of reinstatement, arrears of salary, and damages wherever necessary. If the consequent relief is not claimed then the court would not entertain the suit for declaration.[cvi] Where in a suit a relief was only to a declaration for reinstatement in service of the State Government it was held in such proceedings, arrears of salary and other consequential relief could not be granted.[cvii]
The further relief contemplated is against the defendant and not a third party. Thus, where a property is under attachment, it is enough to file a declaratory suit against the defendant claiming title to the property and no further relief for delivery of possession is necessary. As the Supreme Court has observed: "The authorities clearly show that where the defendant is not in possession and not in a position to deliver possession to the plaintiff, it is not necessary for the plaintiff in a suit for declaration of title to property to claim possession."[cviii]
A question may be raised as to why a plaintiff will not pray for consequential relief when it arises out of declaration. One reason is that the plaintiff may not be sure of the consequential relief. Another important reason appears to be the court-fees. The Court-fees Act 1870 regards a suit for declaration with consequential relief as distinct from that for a declaration simpliciter. In the former, the court-fee is to be computed according to the amount of the relief sought; in the latter case, only a fixed nominal fee is payable. Therefore, a plaintiff may like to go in for a declaration simpliciter to save on court-fees.
The Law Commission expressed the opinion that the proviso to s. 34 should be abolished. It observed:
“The proviso was introduced by the Specific Relief Act with the object of preventing multiplicity of proceedings. The proviso has, however, given rise to a mass of case-law as to what is 'further relief' and whether, 'further relief' is such relief as could be sought for in the suit in which or in the Court before which the declaration is sought. It leads to injustice in many cases and it only results in an addition to the revenue to a certain extent.”
As stated earlier, until a case is decided there is often a good deal of uncertainty whether the plaintiff could have claimed the consequential relief or not.[cix] The recommendation of the Law Commission was not implemented when the Specific Relief Act, 1963 was enacted. If the law is modified as suggested by the Law Commission, declaration may come to serve as a useful remedy in administrative law as an alternative to writs and thus some pressure of work may be eased from the High Courts.
Giving of declaratory relief is discretionary with the Court. The Supreme Court has ruled in Mysore S.R.T. Corp. v. Mirja Khasim[cx] that the discretion exercised by the lower court can be reversed by the superior court only if the discretion is not exercised by it in the spirit of the statute or fairly or honestly or according to the rules of reason and justice.
 A court may refuse to give the declaration if it would be a useless and infructuous relief. A court does not grant a declaration when it has no utility.[cxi] For example, when the prayer for consequential relief is for mandatory injunction and the court would not grant it in the circumstances of the case[cxii], or because of events subsequent to the filing of the suit (such as subsequent legislation passed retrospectively), the suit becomes useless.[cxiii]
The court did not grant a declaration in 1942 that a licence should have been renewed by a Municipality for the year 1936-37 as such a declaration was useless.[cxiv] The relief may also be refused in other suitable cases, e.g., where another appropriate or alternative legal remedy is available.[cxv] A declaration was sought that a bill passed by the legislature was ultra vires. The plaintiff apprehended that after the receipt of the Governor’s assent the bill would become Act and when enforced would adversely affect his property rights. The court refused the declaration saying that the grant of such a relief lay entirely within the Court's judicial discretion and a party cannot claim it as a matter of law during its formative stages.[cxvi]
The declaratory remedy lies by way of suit which normally has to be filed before the District Court. In spite of several advantages in favour of the declaratory action, it is not as popular and effective a remedy as the writs. The reasons are the same as in the case of injunctions. Firstly, since a declaratory decree is a statutory remedy it can be excluded by a Statute.[cxvii] Secondly, two months' notice under s. 80, CPC has to be given before a suit for declaration against the government can be filed.[cxviii] Thirdly, a suit for declaration is to be filed in a lower court where its disposal takes long while a person can go straight to the High Court for a writ.

03. The English Position

In England, the most interesting development in the area of administrative law has been the raise of the action for a declaration as a means of challenging decisions of administrative tribunals as an alternative to certiorari.[cxix] It has developed into a useful, popular and an efficient remedy, to challenge ultra vires acts of administrative authorities. The landmark case in England is Dyson v. Attomey-General[cxx] where the Court of Appeal justified a subject testing the justifiability of action of government officials purporting to act under statutory provisions. Declaration has been used in a number of cases as a means to circumvent the technicalities of certiorari when administrative authorities act against law.[cxxi] Declaration can be granted whether or not any consequential relief is or can be claimed. Another major advantage of declaration over prerogative remedies is that it is a good substitute for remedies which cannot be granted against the Crown, such as, injunction and mandamus. With the introduction of new procedure “application for judicial review" in 1977 which made the declaratory action interchangeable with the prerogative remedies, the former advantage of declaration has been lost.

06. SUIT FOR DAMAGES

Damages are available as a remedy in judicial review in limited circumstances. Compensation is not available merely because a public authority has acted unlawfully. For damages to be available there must be either:
(a) A recognized ‘private’ law cause of action such as negligence or breach of statutory duty or;
(b) A claim under Human Rights Act.
(c) Any another legally recognized right.
The formula that no suit shall lie for anything done or purported to be done in good faith under the Act has been held to include an 'omission' as well.[cxxii] Section 117 of the Factories Act, 1948 provides indemnity in respect of 'anything done or intended to be done under this Act'. It was held that protection conferred can only be claimed by a person who can plead that he was required to do or omit to do something under the Act or that he intended to comply with any of its provisions. The clause cannot confer immunity in respect of actions which are not done under the Act but are contrary to it.[cxxiii] This formula bars suits for damages and compensation for administrative acts done under the Act.[cxxiv] In this connection, the Bombay Port case may be referred to.
The plaintiff had imported certain goods. The Bombay Port Trust delivered a part of the goods to the plaintiff but could not deliver the rest as they were not traceable. He brought a suit after the six-month time limit. As stated earlier, the court had ruled that “omission to do an act" was covered by the expression "act done". The plaintiff argued that the failure to do what the Act mandated: the Port Trust to do, viz., to deliver the goods goods, could not be "in pursuance of this Act." It was held that though the authority might have neglected to comply with the law, yet the ouster clause gave protection to it, as the act of non-delivery was in the discharge of official duty under the Act. There has to be a reasonable or legitimate connection between the act or omission and the discharge of official duty. The short delivery of the goods was in purported exercise of the bailee's obligation under the Act and was covered by s. 87.
The ouster clause will not cover the case of breach of contract. In Bombay Housing Board v. Karbhase Naik & Co.[cxxv], it was held that non-payment of an amount of money due to the respondent on the basis of breach of contract between him and an administrative authority could not be said to be an act done or purported to be done in pursuance of the Act under which the said authority functions but is an act under the contract. While the authority may have entered into the contract in pursuance of the Act, the breach of contract cannot be regarded as having any reasonable connection with any duty cast upon the authority by the Act. Therefore, the privative (ouster) clause would not apply. Similarly, the ouster clause will not prevent a person from suing the government for the recovery of the price for the goods supplied to it, under s. 70 of the Indian Contract Act, 1872.[cxxvi]
S. 68 of the M.P. Excise Act, 1915 bars suits against the government in respect of “anything done" in pursuance of this Act, unless the suit is instituted within six months from the date of the act complained of. The plaintiff was granted a licence for retail sale of country liquor after an auction. The Government undertook to supply a minimum quantity of liquor for sale. But the government defaulted in fulfilling its undertaking. The plaintiff sued for compensation for breach of contract. The High Court ruled that s. 68 would not come in the way as the plaintiff's complaint did not relate to an act done or omitted by the state under the Act. . His complaint related to recovery of damages for breach of a contractual obligation which would not fall within the scope of s. 68.[cxxvii] Under Section 119 of Ajmer Land and Regulation Act, 1877 adoption by a widow was confirmed by Central Government. The aforesaid adoption was challenged in a civil suit. It was held that jurisdiction of civil court is not barred as the adoption itself was challenged in civil suit and issue raised in civil suit was outside the scope of ouster clause.[cxxviii]

07. OTHER REMEDIES

01. Specific Statutory Remedies

Apart from the general remedies mentioned above, a statute imposing a specific obligation on a person, or conferring power on an administrative body, may provide a specific mechanism of its own to invoke the jurisdiction of a Court in some way at some stage of the proceedings for some purposes. For example, s. 18 of the Land Acquisition Act, 1894 enables a person, whose land has been acquired, but who has not accepted the award of compensation for the same, by written application to the collector, to "require that the matter be referred by the collector, for the determination of the court." He may claim this right whether his objection be to the measurement of the land, or the amount of compensation, or the persons to whom it is payable, or the apportionment of the compensation amongst the persons interested. After a reference by the collector to the court, the matter assumes a judicial complexion. The Court may award any compensation between the amount awarded by the collector and the amount claimed.[cxxix] Whenever such an application is made to the Collector to make a reference of the question of compensation to the court, it is the duty of the collector to make the reference unless there is a valid ground for rejecting the application, as for instance, it is time barred.[cxxx] The condition regarding limitation is a sine qua non for a valid reference by the collector. It would, therefore, appear that when a person concerned makes a request to the collector to make a reference to the court for determining the question of compensation, and if the collector does not take any action on it, the person concerned would be entitled to go to the High Court under Art. 226 for a writ of mandamus asking the collector to discharge a duty which he is bound to do under the law. The collector's duty to make the reference is mandatory and not discretionary unless he has a valid ground to refuse to make the reference. In a case where the compensation is determined by Land Acquisition Officer on account of acquisition of land, on filing of an application under Section 18 of Land Acquisition Act, 1894 by the claimant, the Collector is under an obligation to make a reference.[cxxxi]
Some statutes provide for an appeal from the decision of the authority concerned to a court. s. 169 (1) of the Delhi Municipal Corporation Act, 1957 provides that "an appeal against the levy or assessment of any tax under this Act shall lie to the court of the district judge of Delhi." Under s. 169(2), questions of law may be referred by the court to the High Court for decision. Under s. 15 of the U.P. Motor Vehicles Taxation Act, 1935 an appeal could be filed against the order of the assistant transport commissioner within 30 days. Section 6-A of the Essential Commodities Act, 1955 confers power on the collector to confiscate any essential commodity seized in pursuance of an order made under s. 3 of the Act in relation thereto. Section 6-B confers a duty on the licensing authority to give a notice informing the person to whose detriment the action is proposed to be taken, the grounds on which it is proposed to confiscate the essential commodity and further give him an opportunity to make a representation within a reasonable time and also a reasonable opportunity of being heard in the matter. Section 6-C provides for an appeal against the order of confiscation. The state government is required to appoint a "judicial authority" to entertain and hear appeals against the order of confiscation. The appellate authority so constituted has power to modify or annul the order of confiscation. In one instance, the state government appointed the sessions judge as the judicial authority’ for purpose of s. 6-C. The question raised in Thakur Das v, State of Madhya Pradesh[cxxxii] was whether the sessions judge was a "persona designata" and so not, or whether he was, an inferior court subordinate to the High Court for the purposes of ss. 435 and 439 of the Criminal Procedure Code. There was a cleavage of opinion among the High Courts on this point. Some High Courts refused to treat the judicial authority as an inferior court, as in Mysore v. Pandurang P. Naik[cxxxiii]; Gujarat v. C.M. Shah[cxxxiv]; Madhya Pradesh v. Basant Kumar, Jabalpur[cxxxv]. Some High Courts regarded him as an inferior court, as in Public Prosecutor v. L. Ramayya.[cxxxvi]
The Supreme Court explained that the term "Judicial authority" clearly indicated that the appellate authority must be one such preexisting authority which was exercising judicial power. Such an authority has its own hierarchy of superior and inferior courts. The concept of appeal "inheres hierarchy and the appellate authority broadly speaking would be higher than the authority against whose order the appeal can be entertained." Therefore, the sessions judge is to function as a court while hearing appeal from the order of confiscation and this court would be subject to the revisional jurisdiction of the High Court.
Under the Advocates Act, 1961, the disciplinary committee of a State Bar Council has power to impose punishment on an advocate for professional or other misconduct. The concerned advocate has a right to appeal to the Bar Council of India. Every such appeal is heard by its disciplinary committee. Finally the advocate can appeal to the Supreme Court.[cxxxvii] Explaining the scope of appeal, the Supreme Court has emphasized in Chandra Shekhar Soni v. Bar Council of Rajasthan[cxxxviii] that as a general rule, the court would not interfere with the concurrent finding of fact given by the disciplinary committee of the Bar Council of India and the State Bar Council “unless the finding is based on no evidence or it proceeds on mere conjectures and unwarranted inferences".[cxxxix]
Some statutes confer a limited power of judicial review of questions of law. An oft-repeated formula found in the statutes in this regard is to give to the authority concerned the power of making a reference on a law point to the court, usually the High Court. In some cases, the court is also given a compulsive power to require the authority to make a reference to it on a point of law which may have arisen in a case. One illustration of this technique is to be found in the Stamp Act, 1899 where, under s. 57, the Chief Controlling Revenue Authority may state any case to the High Court concerned along with its own opinion thereon. Explaining the implications of this provision, the Supreme Court has stated that the power contained in this provision is “in the nature of an obligation or is coupled with an obligation and under the circumstances can be demanded to be used also by the parties affected by the assessment of the stamp duty.”[cxl] It is a duty cast on the authority, as a public officer, to do the right thing and when an important and intricate question of law in respect of construction of any document arises, it is his duty, as a public servant, to make the reference. If he omits to do so, it is within the power of the court to direct him to discharge that duly and make a reference to the court. It will thus be seen that although the statutory provision only confers on the authority concerned a power to make a reference to the High Court, by a process of judicial interpretation the same has been converted into an obligation, a duty, on it.[cxli] Also, it is not necessary for a party to move the authority by way of an application for making a reference to the High Court. The authority may itself act suo motu and refer a case to the High Court even without an application from the aggrieved assessee.[cxlii] It is not only the authority that can make the reference; it is open to the High Court as well, in pursuance of a petition to it under Art. 226, to direct the authority to make a reference to the court in case it omits to do so when an important question regarding the interpretation or construction of a document is involved in a case. Furthermore, the authority is competent to make a reference when the case is pending before it and not after it has closed the case and passed the final order; but the High Court acting under Art. 226 is not bound by any such restriction, and it can require the authority to state a case even after it has closed the case and made the final order.[cxliii] In Sarup Singh,[cxliv]  the authority imposed a stamp duty of over Rs. 3000 on the document in question and a penalty of an equal amount. The question was whether or not the document in question was a gift deed and so subject to the stamp duty levied by the authority. On a writ petition under Art. 226, the High Court directed the authority to refer the question with its opinion thereon to it under s. 57. The jurisdiction of the High Court extends to the entire case; it can consider any question of law which emerges in the case and the court is not confined merely to such questions as may be referred to it by the authority.[cxlv]
The example par excellence of the reference technique is furnished by several Central Statutes. Section 35H of the Central Excise Act, 1944 provides that the Commissioner of Central Excise or the other party may within 180 days of the date on which he is served with the notice of an order under Section 35C, may by application in the prescribed form apply to the High Court to direct the Appellate Tribunal to refer to the High Court any question of law arising from such order of the Tribunal. Similarly Section 57 of the Indian Stamps Act, 1899 empowers the Chief Controlling Revenue Authority to state any case referred to in Section 56 (2) of the Act, if it arises in a State, to the High Court of that State. If only questions of fact arise from a tribunal order, and no point of law arises, the High Court will be justified in declining to give direction to the tribunal to refer a case to it.[cxlvi]
The limitations of this procedure may be noted. In the first place, only questions of law can be referred. This means that the tribunal is the final authority in regard to questions of fact.[cxlvii] Where in a petition or reference under Section 256[cxlviii] of Income Tax Act, 1961 a question of fact is raised, it cannot be referred.[cxlix]
The question whether surplus realized on sale of shares is a capital gain exempt under section 47(iv) of the Income-tax Act, 1961, is a question raising mixed issue of law and fact, accordingly the matter was directed to be referred to High Court by IIAT.[cl] Secondly, only such questions of law may be referred as arise out of the order of the Tribunal. This means that new questions of law cannot be referred to the High Court for opinion. The reference technique thus differs from the appeal technique in so far as in the latter case new questions of law if they arise from established facts may be urged before the appellate forum,[cli] but the same cannot be done through the reference technique. The idea underlying this restriction is to protect the High Court from being flooded by income tax cases delaying both the judicial as well as the tax assessment processes.[clii] What is a question of law arising out of the order of the Tribunal? Answering this, the Supreme Court has laid down the following propositions;[cliii]
(1) When a question is raised before the tribunal and is dealt with by it, it is clearly one arising out of its order;
(2) when a question of law is raised before the Tribunal, but it fails to deal with it, it can be deemed to have arisen out of its order;
(3) When a question is not raised before the tribunal but it deals with it, that will also be a question arising, out of its order;
(4) when a question of law is neither raised before the tribunal nor considered by it, it will not be a question arising out of its order notwithstanding that it may arise out of the findings given by it.
What the Supreme Court means by "question of law" in the above propositions is a ‘legal issue’ which is a broader term than the former. To prove a legal issue, the person concerned could adduce several legal points or contentions. Though a new legal issue cannot be raised, yet a new legal point or contention can be adduced in support of the issue. In the Scindia case,[cliv] the question referred to the High Court was whether a certain sum received by the company "was properly included in the assesse company's total income computed for the assessment year 1946-47". Before the High Court, the company raised a completely new contention for the exemption of the sum from the tax. The Supreme Court held that that could be done because "it is competent for the court in such a case to allow a new contention to be advanced, provided it is within the framework of the question as referred". However, no new additional evidence could be permitted to be raised at that stage.[clv] The High Court in a reference under Taxation statute exercises advisory jurisdiction in regard to questions of law. The High Court cannot, in reference proceedings, go behind the facts found. It cannot look at the evidence that was not before the tribunal when the tribunal recorded the impugned findings, to hold that findings are perverse.[clvi]
It is well settled that a reference court cannot go into the vires of an Act. It is based on the assumption of a notion of physical law that a river cannot rise above its source.[clvii]
Though the tribunal is the final judge of facts, yet if there is no legal evidence to support the facts found by the tribunal, or the findings are unreasonable or perverse, then it may be regarded as a question of law and the court may quash the findings on a reference being made to it by the tribunal.[clviii] The Supreme Court has reiterated in Amarchand Sobhachand v. C.I.T.[clix] that where a finding of fact by the Income-tax Appellate Tribunal is supported by evidence, it is binding on the court in the exercise of its jurisdiction under Art. 136. But the position of a mixed question of law and fact is different. The High Court can interfere if the tribunal has misdirected itself in law. Such a question does not have the same unassailability as a pure finding of fact. Where the tribunal misdirects itself in applying the law to the facts as found by it, the court can interfere with the same as this gives rise to mixed questions of law and fact.[clx] Jurisdiction under Section 256 of Income-tax Act, 1961 cannot be exercised in respect of findings of fact, though amount involved may be large.[clxi]
The High Court can interfere with finding of fact given by ITAT if the finding of fact in a question referred to it appears to be perverse. Otherwise the High Court is bound to proceed upon such findings of fact to answer question of law. ITAT is the final fact finding authority.[clxii]
The reference procedure has been criticized by the Law Commission of India on the ground that many a time the statements of the case drawn up by the tribunal for reference to the High Courts have been perfunctory so much so that the High Courts have had to remit the cases to the tribunal for a further and better statement of the case with fuller particulars.[clxiii]
From the decision of the High Court on a reference made by the tribunal, an appeal may go to the Supreme Court in any case in which the High Court certifies it to be a fit case for appeal. The High Court has to exercise its power of certification not mechanically but after applying its mind judicially and the Supreme Court may decline to hear a case if in its view the certificate has not been granted properly by the High Court. When the High Court granted a certificate containing a bold statement that the case was a fit one for appeal to the Supreme Court, the court held the certificate to be invalid, and refused to hear the appeal.[clxiv] The Supreme Court can also hear an appeal under Alt. 136 from a High Court's decision in a reference. In appeal, the Supreme Court would not exercise any wider power than the High Court does in a reference.[clxv] Besides, if the tribunal is of the opinion that, on account of conflict in the decisions of the High Courts in respect of any particular question of law, it is expedient that a reference be made direct to the Supreme Court, the tribunal may draw up a statement of the case and refer it through its President direct to the Supreme Court. It is thus possible for the tribunal to refer a question of law direct to the Supreme Court so that conflict of judicial opinions thereon may be resolved. This helps in securing uniformity in the interpretation of the income tax law.
Apart from the reference procedure, there are possibilities of judicial review in income tax proceedings through Arts. 32, 226 and 136 of the Constitution. In spite of the reference procedure laid down in the Income-tax Act, resort is still had to the High Court under Art. 226 in quite a large number of income tax cases. Generally speaking, these are cases which are not covered by the reference procedure, such as, matters in which no appeal lies to the tribunal and hence no reference can possibly be made by it to the High Court. One such situation arises when a taxpayer seeks to appeal to the Appellate Assistant Commissioner against the order of the income tax officer. In such a case, the income-tax officer has a discretion to stay payment of the tax pending appeal. If he refuses to stay tax payment, no appeal lies against the order to the tribunal- If the income tax officer exercises his discretion improperly, relief can be had from the High Court under Art. 226.[clxvi] Further, the High Courts have also intervened, under Art. 226, when the exercise of jurisdiction by an income tax officer was patently wrong, e.g., where he sought to assess a person to tax after the clear expiry of the period of limitations,[clxvii] or without the issue of the preliminary notice as required by the statute,[clxviii] or against the clear language of the statutory provision,[clxix] or when the income tax officer assumed jurisdiction by deciding a jurisdictional fact erroneously.[clxx] Where such special circumstances were not present, the High Courts have refused to intervene.[clxxi] The answer to the question whether the writ jurisdiction is muzzled by statutory finality of orders regardless of their illegality, is in the negative.[clxxii]
The Court should be reluctant to interfere against mere issuance of a show cause notice. Adjudication proceedings must not be stalled.[clxxiii]
Where the validity of notice issued under Section 148 of Income-tax Act, 1961 is challenged the High Court should not go into the question whether the notice is partly valid and partly invalid.[clxxiv]
Finally reference may be made to s. 115 of the C.P.C. This provision enables the High Court to call for the record of any case decided by any "court subordinate" to the High Court and make such order as it thinks fit if the subordinate court has acted outside its jurisdiction, or has failed to exercise its jurisdiction or has acted illegally or with material irregularity in exercising its jurisdiction. The provision is operative only when no appeal lies from the subordinate court to the High Court.
 The question has been raised whether the term 'court' in s. 115 can be interpreted in a broad sense so as to include tribunals and quasi-judicial bodies. This will mean that the High Court will have a review power on all such bodies. There has been a difference of opinion among the High Courts on this point. A claims tribunal constituted under Motor Vehicles Act, 1988 has been held to be a civil court for purposes of s. 115.[clxxv] In some cases, the authority under the Payment of Wages Act, 1936, has been held to be not subordinate to the High Court within the meaning of s. 115, C.P.C..[clxxvi] In Yeshvant Rao v. Sampat,[clxxvii] the Madhya Pradesh High Court ruled that the commissioner for workmen's compensation would not fall within the purview of s. 1 is. Under s. 19(2), Workmen's Compensation Act, the Commissioner decides any question as to the liability of any person to pay compensation or as to its amount or duration. The Commissioner has all powers of a civil court to take evidence on oath or compel attendance of witnesses. While there may be some similar features between a court and a tribunal, e.g., both can give binding decisions, both follow a similar procedure, except that the tribunal's procedure may not be as strictly prescribed as that of a court, the two also differ insofar as a court is a part of the ordinary hierarchy of courts while a tribunal is constituted under a special statute to exercise some special jurisdiction. The High Court opined that the word 'court' in s. 115 has been used in a narrow sense, meaning only a 'civil court in the normal hierarchy of courts'. S. 115 does not include tribunals and so an order passed by the Commissioner under s. 19, would not be reviewable by the High Court. There are, however, some contrary pronouncements as well.[clxxviii] In any case, under Art. 227, the High Court can always exercise review power over such bodies. Under Section 115 of the Civil Procedure Code, order of proceedings sought to be scrutinized must be that of subordinate authority or of court.[clxxix]

08. OUSTER CLAUSE IN ADMINISTRATIVE LAW AND PRIVATE LAW REVIEW

01. Ouster Clauses

It is becoming rather common for the legislature to confer decision making powers on various authorities and to seek to limit or exclude court's power to review those decisions. In India, because of Art. 226 of the Constitution, the writ system is entrenched and thus no statutory provision can affect High Courts' power to issue a writ. But the position is different when a person wishes to seek an ordinary remedy through a suit for injunction, declaration, or any other appropriate relief. S. 9 of the CPC being a statutory provision, its scope can be curtailed by another statutory provision. S. 9 C.P.C. itself envisages that this jurisdiction of the civil court may be excluded expressly or implicitly. CA question arises from time to time as to how far an ouster or privative clause, i.e., a provision in a statute seeking, to exclude courts' review power affects the ordinary remedies.
The question is significant in the modern context when the legislature freely establishes bodies enjoying large discretionary powers and at the same time seeks to make their decisions free of judicial review. Not all decisions made by such bodies raise any policy issues which may justifiably be characterized as non-justiciable. In most of the cases, the contest is between a citizen and the administration, and the matter is decided by an authority aligned with the administration, and to make such a decision non-reviewable by the Courts would seem to be an extremely one-sided arrangement. In such a case, at no stage, there is an objective assessment of the legal rights of the concerned citizen. These decision-making bodies may tend to act as petty despots in the absence of any independent judicial control from the above. True, in India, writ jurisdiction can always be invoked. This is a built-in safeguard of great consequence (against misuse of administrative power, but it may not always be possible for all and sundry to go to the High Court to vindicate their rights. It is necessary that a remedy be available to a citizen nearer at hand. From this point of view, remedy by way of suit ought to be available to him which he can invoke in the lower court at less expense. Denial of judicial remedies at lower level only increases the burden of the High courts. Then, there are many questions which cannot be satisfactorily resolved through the machinery of a writ-petition. For example, High Courts are reluctant to go into questions of fact in a writ petition;[clxxx] writ is not regarded as a suitable remedy for seeking refund of money illegally collected by the administration as a tax,[clxxxi] or for impeaching contractual obligations.[clxxxii] For any such purpose, one has to resort to the remedy by way of suit. If that approach to justice is barred by a statutory provision, the citizen may be left high and dry with no effective remedy to vindicate his rights against infringement at the hands of the administration. Unfortunately, not much attention has so far been directed towards improvement of ordinary remedies against the administration because of the availability of the writ system, but development of ordinary remedies is intimately connected with the idea of easy access to justice by ordinary persons.
Statutes use various ouster or privative clauses to exclude court review of administrative action taking place under them. It is not possible to take note of all the variants of such formulae, but the following four appear to be typical and are used most often:
First, a statute may provide that no suit shall lie for anything done or purported to be done in good faith under the statute.
Two, a statute may provide that the order or the decision of a specified body or tribunal functioning thereunder shall be 'final'.
Three, a variant of this provision may lay down that no order made under the Act shall be called in question in any court.
Four, a statute may permit the filing of a suit subject to some limitations, such as, giving notice to the authority concerned before filing the suit, usually the duration of the notice being two months; another condition may be that a suit must be filed within the prescribed limitation period, may be, six months from the accrual of the cause of action. If the statutory conditions are not fulfilled, the suit is barred.

02. Scope of Exclusionary clauses

The extent of exclusion will largely depend upon a construction of the provision enacted for that purpose but in case of doubt it is a familiar approach to correlate the section excluding civil court's jurisdiction with other sections in the same statute providing special remedies,[clxxxiii] for a contrary construction would lead to a vacuum.[clxxxiv] Absence of a provision to enable an authority or tribunal for holding an inquiry on a particular question is indicative that jurisdiction of civil courts on that question is not excluded; whereas the very provision setting up hierarchy of judicial tribunals for the determination of a question, is sufficient in most cases for inferring that the jurisdiction of the civil courts to try the same matter is barred.[clxxxv] But when with the object of speedy adjudication of certain matters which are widely defined, jurisdiction is conferred on tribunals or special courts and jurisdiction of normal courts is excluded, the wide language used cannot be narrowly construed,[clxxxvi] and it is now a well established principle that the jurisdiction of a court created specially for reduction of disputes of certain kinds should be construed Iiberally.[clxxxvii] Further, when jurisdiction of civil courts in a particular matter is excluded by transferring that jurisdiction from civil courts to tribunals or authorities, it is presumed that such tribunals or authorities can draw upon the principles of procedure in civil procedure code, though not expressly made applicable, to ensure fair procedure and just decision unless such principles are inconsistent with the provisions of the Act constituting them.[clxxxviii]
Even in cases where jurisdiction is excluded by use of prima facie comprehensive language, it is open to civil courts which are courts of general jurisdiction to decide whether a court, or tribunal or authority having limited jurisdiction, has acted in excess of its statutory powers.[clxxxix] In other words, civil courts can interfere when the order of the tribunal or authority is really not an order under the Act conferring special jurisdiction but is a nullity.[cxc]
But on matters on which jurisdiction of the civil court is excluded, neither consent of the parties nor an order of the special tribunal which has jurisdiction to decide those matters, can confer jurisdiction on the civil court.[cxci]
Section 10 of the Indian Railways Act, 1890, provided that a railway administration shall do as little damage as possible in exercise of its powers for construction and maintenance of work, and compensation shall be paid for any damage caused by the exercise thereof and that ‘a suit shall not lie to recover such compensation; but in case of dispute the amount thereof shall on an application to the' Collector, be determined and paid in accordance with the provisions of the Land Acquisition Act, 1894.’ In a suit brought by a person claiming damages for injury caused by negligence of a railway administration in construction of certain works, it was contended that the suit was barred by section 10 of the Railways Act. This contention was negatived on the ground that the aforesaid provision was applicable only when the railway administration had not exceeded or abused its powers, and was not guilty of negligence.[cxcii] Lord MacNaghten in delivering the judgment of the Board said: "It has been determined over and over again that if a person or body of persons having statutory authority for the construction of works exceed or abuses the powers conferred by the Legislature, the remedy of a person injured in consequence is by action or suit, and not by a proceeding for compensation under the statute which has been so transgressed. Powers of this sort are to be exercised with ordinary care and skill, and with some regard to property and rights of others. They are granted on the condition sometimes expressed and sometimes understood-expressed in the Act of 1890, but if not expressed always understood that the undertakers shall do as little damage as possible in the exercise of their statutory powers.”[cxciii] In an earlier Privy Council case[cxciv] it has been pointed out that where a public body, acting in execution of a public trust and for a public benefit does an act which, it is authorized by law to do, and does it in a proper manner, though the act so done works a special injury to a particular individual the individual injured cannot maintain an action and he is without a remedy unless remedy is provided by the statute. But the position is different when the power is exercised ‘arbitrarily, carelessly or oppressively' and when an action is brought in such cases Lord MacNaghten said: "In a word, the only question is: Has the power been exceeded? Abuse is only one form of excess.”[cxcv] In HALSBURY'S Laws of England the legal position is summed up as follows: "It is the duty of persons upon whom statutory powers are conferred to keep strictly within those powers. If such persons act in excess of their powers, they are to the extent to which they exceed their powers, deprived of any protection conferred upon them by the statute in question and will be subject to the ordinary remedies existing at common law. An injunction may be granted to restrain an act in excess of statutory powers and a person injured by such an act may be entitled to recover damages from the persons purporting to exercise the power.”[cxcvi]
The question was considered in relation to municipal taxation in Firm Radhakrishnan v. Ludhiana Municipality.[cxcvii] After referring to the Privy Council decisions noticed above,[cxcviii] SUBBARAO, J. observed: "A suit in civil court will always lie to question the order of a tribunal created by a statute, even if its order is, expressly or by necessary implcation, made final, if the said tribunal abuses its power or does not act under the Act but in violation of its provisions.”[cxcix] In the last-mentioned case[cc] it was held that an assessment of terminal tax, which was questioned on the ground that the Municipality applied a wrong rate of tax by wrongly determining the character of taxable commodity, was not open to challenge in the civil court; but it was pointed out that if a municipality levied a tax on a commodity which was not taxable at all, a civil suit will lie; the former being a case where the municipality acts under the Act although wrongly, whereas the latter is a case where the entire action is outside the Act. So in Poona City Municipal Corporation v. Dattatraya Nagesh Deodhar[cci] the Supreme Court upheld the maintainability of a suit for recovery of money which the Municipal Corporation detained as a 'tax on octroi refund' on the ground that the Corporation had no power to levy such a tax. It was further held that the action of the Corporation in levying such a tax was not ‘any act done or purported to be done in pursuance or execution or intended execution' of the Corporation Act.[ccii] Similarly in Bharat Kala Bhandar v. Dhamangaon Municipality[cciii] a suit to claim refund of tax on professions, trades and callings levied and collected by the Municipality in excess of constitutional limits prescribed by section 142-A of the Government of India Act, 1935, and Article 276 of the Constitution, was held to be maintainable. It was pointed out that the suit did not relate to anything done or purported to be done under the Act; and the special procedure of notice and limitation prescribed by the Act did not apply. It was further held that the suit was not barred by a statutory provision in the Act which was to the effect: 'No objection shall be taken to any valuation, assessment or levy in any other manner or by any other authority, than as provided in this Act.' And in Kripal Singh v. Municipal Board, Ghaziabad,[cciv] a suit claiming refund of toll tax based on a statutory exemption was not held to be barred though the plaintiff had not complied with the rules prescribing the procedure for claiming refund of such tax from the municipality. It was also held that the suit was not in respect of any act done or purported to be done in the official capacity. The decision in Firm Radha Krishan’s case[ccv] however, does not allow challenge to an order of assessment of tax on the ground that it is erroneous or incorrect. The challenge will be permissible only if the assessment is constitutionally invalid or is entirely without jurisdiction. This has been explained in the case of Bata Shoe Co. Ltd. v. Jabalpur Corporation.[ccvi] In this case the plaintiff instituted a suit to challenge the order reopening an assessment of octroi tax and levy of double penalty by a suit on the ground that the assessment was made without any authority and that the imposition of double penalty was not justified under the provisions of the relevant Municipal Act and the Rules. The Act provided an elaborate machinery of its own for challenging an assessment of tax. The Act also provided that 'No objection shall be taken to any valuation, assessment or levy nor shall the liability of any person to be assessed or taxed be questioned in any other manner or by any other authority than as provided in this Act'. The Supreme Court held that the suit was not maintainable on the reasoning that if the appropriate authority while exercising its jurisdiction and powers under the relevant provisions of the Act, holds erroneously that an assessment already made can be corrected or that an assessee is liable to pay double duty under the relevant rule when the rule does not in fact justify such an imposition it cannot be said that the decision of the authority is without jurisdiction.
In Income-tax and Sales Tax Acts, it is common to find provisions to the effect that 'no suit shall lie to challenge an assessment made under the Act', or that 'no assessment made under the Act shall be called into question in any court except as otherwise provided in the Act'. In Raleigh Investment Co. v. G.G. in Council,[ccvii] the Privy Council construing a provision of this nature (section 67 of the Income-tax Act, 1922) held that an assessment could not be challenged in civil court on the ground that it was based on a provision of law which was ultra vires. It was pointed out that the correct meaning of the phrase 'assessment made under the Act' is an assessment finding its origin in an activity of the assessing officer acting as such, and that an assessment under the machinery of the Act relying on a provision which is later found ultra vires is not a nullity but only erroneous in law. This Privy Council decision has not been accepted by the Supreme Court. In K.S. Venkatraman & Co. v. State of Madras[ccviii], it was held by the Supreme Court that an assessment which is based on a charging section which is ultra vires is not an 'assessment under the Act', and a suit to challenge such an assessment is not barred. It was also held that assessing authorities cannot entertain a question relating to validity of the Act, and hence, it is open to a civil court to entertain and decide such a question notwithstanding that assessment has already been made. This case was followed in Dhulabhai v. State of Madhya Pradesh[ccix], where assessment was based on a notification issued under the charging section. The notification contravened Article 301 of the Constitution and was, therefore, ultra vires. It was held that the validity of the notification could not have been gone into by the assessing authorities, and that the assessment was not ‘under the Act', and could be challenged by a suit in civil court. Income-tax and Sales Tax Acts, however, contain an elaborate machinery for assessment and for determination of questions of fact and law arising in assessment proceedings and an assessment cannot be questioned except in the manner provided under the Act on the ground that it is erroneous in fact or in law.[ccx] Thus, if purchases only and not sales can be taxed, a suit challenging an assessment is not maintainable on the ground that the transactions taxed were sales and they were wrongly held to be purchases by the assessing authorities.[ccxi] Similarly if sales taking place inside a State are alone taxable, a suit to challenge the assessment 'is not maintainable on the ground that the sales were in fact outside sales and were wrongly held to be inside sales.[ccxii] In this connection it must be kept in mind that speaking generally the taxing authorities have authority to decide finally even collateral questions of fact and law touching their jurisdiction.[ccxiii] The factors that liability to pay income-tax or sales tax is a creature of the taxing Act which normally provides an elaborate machinery for assessment; that the taxing authorities have in genera! authority to decide finally questions of fact and law pertaining to their own jurisdiction; and that these Acts usually contain an exclusionary provision expressly restraining a suit to challenge an assessment made under the Act, leave little room for a suit to challenge an assessment. In addition to the case where assessment is based on an ultra vires provision, assessment may also be open to challenge on the ground that it was made in violation of fundamental principles of judicial procedure e.g., without any notice to the assesse. Indeed, in Mafatlal Industries Ltd. v. Union of India[ccxiv], a nine judge Bench of the Supreme Court while dealing with refund provisions in the Central Excises and Salt Act, 1944 and the Customs Act, 1962 can be said to have laid down by majority the following general propositions:
(i) A claim for refund of tax on the ground that it has been collected by mis-interpreting or misapplying the provisions of a taxing Act or the rules and notifications made thereunder has to be preferred in accordance with the provisions of the Act before the authorities and within the limitation specified therein and no suit is maintainable in that behalf;  
(ii) Where a refund is claimed on the ground that the provision of the Act under which it was levied is or has been held to be unconstitutional, the claim can be made by a suit or by way of a writ petition for such a claim is outside the purview of the Act; and
(iii) A claim for refund can succeed only when the claimant establishes that he has not passed on the burden of the tax to others; in other words, where the claimant has suffered no real loss or prejudice the claim for refund would be disallowed.[ccxv]
The bar of suits in civil courts, contained in section 293 of the Income-tax Act, 1961, is much wider than the corresponding section 67 of the Income-tax Act, 1922 which was limited to bar a suit 'to set aside or modify any assessment' made under the Act. Section 293 of the 1961 Act bars a suit 'to set aside or modify any proceeding taken or order' made under the Act.[ccxvi] By an order passed under section 132(5) of the Act certain ornaments recovered on search and seized from the premises of an assessee were directed to be retained. The step-mother of the assessee, instead of applying under section 132(11), which provided a remedy for challenging the order, brought a suit for partition ofthe ornaments which was in substance a suit for challenging the proceedings and the order under section 132(5). It was held that the suit was barred under section 293.[ccxvii]
Section 5 of Part I of the Arbitration and Conciliation Act, 1996 provides: 'Notwithstanding anything contained in any other law for the time being in force, in matters governed by this Part no judicial authority shall intervene except where so provided in this Part.' This section along with Section 16 of the Act which provides that 'the Arbitral Tribunal may rule on its jurisdiction' have been widely construed and interference by civil court has been ruled out except as provided in the Act.[ccxviii]
Special provisions curtailing the normal period of limitation for suit or prosecution have also been strictly construed. Section 53 of the Tamil Nadu District Police Act, 1869 prescribes a period of three months for 'all actions and prosecutions against any person which may be lawfully brought for anything done or intended to be done under the provisions of this Act or under the provisions of any other law for the time being in force conferring powers on the police'. Construing this provision it has been held that "to be able to say that an act is 'under' a provision of law, one must discover the existence of a reasonable relationship between the provision and the act."[ccxix]
Therefore, when a person reported to the police in answer to a summons and was beaten and tortured, these acts of the police officer were held to be not 'under' any provision of law and outside the bar of section 53.[ccxx] Similar view has been taken of the corresponding provision in the Kerala Police Act, 1961, where it was held that a police officer in committing torture on a person cannot be said to be 'acting or purporting to act in discharge of his official duty and cannot get the benefit of reduced period of limitation in section 63 of the Act.[ccxxi]
A provision enacted in terms: 'No order made in exercise of any power conferred by or under this Act shall be called in question in any court', assumes that the order is made in exercise of the power, which clearly leaves it open to challenge on the ground that it was not made in conformity with the power conferred.[ccxxii] Similarly a provision using the formula: 'No order or decision under this Act shall be called in question in any court' will not stand in the way of a suit challenging an order or decision when the order or decision is really not an order or decision under the Act but a nullity.[ccxxiii] Therefore, when there is a non-compliance with fundamental provisions of the Act or fundamental principles of judicial procedure which makes proceedings before the tribunal or authority illegal and void, a civil suit to challenge the orders or dicisions passed in such proceedings is not barred.[ccxxiv] The reason is that an order or a decision which is a nullity or void, is not an 'order or a decision under the Act' and jurisdiction of the civil court to challenge such an order is not barred by the exclusionary provision using the above formula. For the same reason even when an order is required to be passed on subjective satisfaction of an authority as to existence of certain matters, a satisfaction based on wholly irrelevant grounds is regarded as no satisfaction and the order based on it can be challenged in a court in spite of the exclusionary clause providing that the satisfaction of the authority "shall be final and conclusive and shall not be questioned in any court of law."[ccxxv]
When a statute authorized the grant of 'proprietary rights' and the Deputy Commissioner made a grant in terms thereof, but in appeal the Commissioner restricted the grant by imposing a condition that the land should not be alienated without the concurrence of the reversioners, the Privy Council held that a suit was maintainable to challenge the condition.[ccxxvi] LORD SIMONDS in delivering the opinion observed:
"Their Lordships have no doubt that the Civil Court has power to entertain a suit, in which the question is whether the executive authority has acted ultra vires.”[ccxxvii] Proceeding further, LORD SIMONDS said: "The specific subject-matter of the grant is the 'proprietary rights', that, and nothing else, may be granted or refused. To purport to grant 'proprietary rights' but to withhold an essential proprietary right, viz., the free power of alienation is neither the one thing nor other. The withholding of such a right may be referred to as a condition, but its effect, as already stated, is to create an estate unknown to the law and to grant not proprietary rights but something which is not susceptible of terms of legal definition. Their Lordships think that the original grant by Deputy Commissioner, who clearly acted within his competence, should stand and the so-called condition imposed by the superior executive authority which was in their view incompetent, should be disregarded.”[ccxxviii]
Section 4 of the Bombay Revenue Jurisdiction Act, 1876, which bars the jurisdiction of civil courts in certain matters has been held not to be attracted when the claim laid in civil courts is on the ground that an act or order of revenue authorities is without jurisdiction and null and void. A suit in civil court is, therefore, maintainable for claiming reliefs on the grounds that an order of the Governor-in-Council made under section 211 of the Bombay Land Revenue Code, 1879, was in excess of his statutory powers;[ccxxix] that a purported sale for arrears of revenue by the Revenue authorities was void and was no sale at all;[ccxxx] and that an order in review was without jurisdiction there being no power of review.[ccxxxi]
The extent of exclusion is, however, really a question of construction of each particular statute and the general principles applicable are subordinate to the actual words used by the legislature.
By use of the words 'a compulsory purchase order shall not be questioned in any legal proceedings whatsoever', it was held by the House of Lords that Parliament excluded every form of challenge including one based on the ground that the order was made in bad faith.[ccxxxii] The correctness of this view was not accepted by the Supreme Court,[ccxxxiii] and also by the House of Lords,[ccxxxiv] in a later case; but it appears that if the exclusionary provision were to the effect that an order made or purporting to be made under the Act shall not be called in question in any Court on any ground whatsoever', it will require great legal ingenuity to support a civil suit for challenging ‘an order purporting to be made under the Act' for even an order which is nullity or void can fall under that description though it cannot be called 'an order under the Act’.[ccxxxv]
Article 372 (2) of the Constitution confers powers on the President to issue adaptation orders 'for the purpose of bringing the provisions of any law in force in the territory of India into accord with the provisions of the Constitution' and further enacts that ‘any such adaptation or modification shall not be questioned in any court of law’. Interpreting this provision it has been held that an adaptation order issued by the President is not open to challenge on the ground that it amounted to more than bringing the existing law into conformity with the provisions of the Constitution,[ccxxxvi] although the order can be challenged on the ground that it was violative of some other provision of the Constitution.[ccxxxvii]
Article 356 of the Constitution provides that if the President ‘is satisfied that a situation has arisen in which the Government of the State cannot be carried on in accordance with the provisions of the Constitution' the President may by proclamation:
(a) assume to himself the functions of the Government of the State;
(b) declare that the powers of the State Legislature shall be exercised by Parliament; and
(c) make such incidental or consequential provisions as may be necessary to give effect to the objects of the Proclamation.
The Article before the Constitution Forty-fourth Amendment Act further provided that the satisfaction of the President 'shall be final and conclusive and shall not be questioned in any court of law'. Interpreting this provision the Supreme Court[ccxxxviii] held that if the satisfaction of the President is based on wholly extraneous grounds which have no nexus with the action taken, the Proclamation can be challenged in a court of law on the ground that the President acted without the required satisfaction in issuing the Proclamation for satisfaction based on wholly irrelevant grounds amounts to no satisfaction. But if there are some grounds which bear some relevance or nexus to the action taken the propriety or sufficiency of satisfaction cannot be challenged in a court of law. Article 356 again came up for consideration before the Supreme Court after deletion of the clause barring judicial review. It has been reiterated that Article 356 confers a conditional power on the President and the Proclamation issued by him is open to judicial review on the grounds that it was a mala fide exercise of power; that it was based on wholly irrelevant or extraneous grounds; that there was no material in support thereof; and that the material relied upon was irrelevant to the action taken.[ccxxxix] If the Proclamation is struck down the court can also restore back the dissolved assembly.[ccxl] But if there is some material which is relevant to the action taken the court will not enquire into its correctness or adequacy.[ccxli]
When certain matters are committed to the jurisdiction of a tribunal or authority, and its determination is made final and civil courts are expressly debarred in exercising jurisdiction over those matters, or in questioning the determination of the tribunal or authority, it will be inferred that all questions of fact and law whether simple or intricate pertaining to those matters have~ be determined exclusively by the tribunal or authority and not by the civil court.[ccxlii] Indeed, it has been said that when a statute gives finality to the orders of a special tribunal the civil courts' jurisdiction must be held to be impliedly excluded in so far as the merits of the case are concerned even though there is no express exclusion of the jurisdiction and that in such a case civil courts have jurisdiction only to examine whether the provisions of the statute have been complied with or the tribunal had or had not acted in conformity with the fundamental principles of judicial procedure) In this case a suit was filed to challenge a scheme of nationalization which was pending consideration under section 68-D of the Motor Vehicles Act, 1939, and it was held that the suit was impliedly barred.[ccxliii] But if the determination of the tribunal or authority is made final only for 'purposes of the Act' which creates the special jurisdiction, the exclusion of civil courts' jurisdiction will not be readily inferred even if the Act in addition to the finality clause provides that the order of the tribunal shall not be questioned in a court of law.[ccxliv] Thus, if the object of the special Act is to serve the revenue purposes of the Government and to facilitate revenue collection, decisions on incidental questions arrived at in a summary manner for identifying and registering persons in the revenue records from whom recovery of revenue is to be made, cannot bar the jurisdiction of civil courts to entertain suits for protection of title and possession of a person who has not been recognized as a ryot under the machinery of the Act.[ccxlv]
An exclusionary clause in an Act which forbids a challenge to 'a determination or order made under the Act' in a civil court contemplates cases of real determination or order and does not protect a determination or order which is a nullity. So no ouster clause can prevent challenge by a civil suit to an order or determination which is a nullity.

09. CONCLUSION

Originally, though more powerful and available to the common man than constitutional remedies, equitable remedies had played a great role in bringing in their life the light of justice through equitable remedies. However, when Indian Judiciary became more powerful by issuing writs frequently and without delay, the comparatively complicated procedure in ordinary remedies of Private Law Review made it unattractive. However, there are certain areas where Judiciary reserves writs and allows ordinary remedies. In such areas the importance of Private Law Review as explained above is greatly appreciated.
The reluctance of the Higher Judiciary to look into facts, where administrative action is challenged, and the concept that remedy is not a matter of right even where administrative action is found defective, when combined with the notion of issuing prayed remedies to the aggrieved parties only in grave violations of procedure, and the acceptance of the discretionary power of administrative action and the denial of prayer on the ground of expenditure of public moneys, very often compel the aggrieved party to resort to Private Law Reviews.
If our courts could avoid inordinate delay in pronouncing their final judgments in suits for injunctions, declarations, damages and other remedies, administrative action may be challenged more easily, through established ordinary legal procedure.


[i] http://www.businessdictionary.com/definition/administrative-law.html
[ii] AIR 1970 SC 150
[iii] (1610) 8 Co Rep 113 b: 77 ER 646
[iv] 1 Cranch 137: 2 L Ed 60 (1803)
[v] Shankari Prasad Singh Deo v. Union of India, AIR 1951 SC 458
[vi] Sajjan Singh v. State of Rajasthan AIR 1965 SC 845
[vii] Golak Nath v. State of Punjab AIR 1967 SC 1643
[viii] Kesavananda Bharati v. State of Kerala (1973) 4 SCC 225
[ix] Minerva Mills Ltd. v. Union of India (1980) 3 SCC 625
[x] Sanjeev Coke Mfg. Co. v. Bharat Coking Coal Ltd. (1983) 1 SCC 147
[xi] Indira Nehru Gandhi v. Raj Narain 1975 Supp SCC 1
[xii] Ajay Hasia v. Khalid Mujib Sehravardi (1981) 1 SCC 722
[xiii] E.P. Royappa v. State of T.N. (1974) 4 SCC 3
[xiv] Maneka Gandhi v. Union of India (1978) 1 SCC 248
[xv] Council of Civil Service Unions v. Minister for the Civil Service (1984) 3 WLR 1174: (1984) 3 All ER 935 (HL)
[xvi] Pearlman v. Governors of Harrow School 1979 QB 56: (1979) 1 All ER 365 (CA)
[xvii] Chandrakumar v. Union of India (1997) 3 SCC 261
[xviii] Chief Constable of North Wales Police v. Evans (1982) 3 All ER 141 at Page 143
[xix] R. v. Lancashire CC, ex p Huddleston (1986) 2 All ER 941 (CA)   p. 945
[xx] Tata Cellular v. Union of India (1994) 6 SCC 651 pp. 687-88, para 94
[xxi] London County Council v. Attorney General 1902 AC 165 (HL)
[xxii] White and Collins v. Minister of Health (1939) 2 KB 838 : (1939) 3 All ER 548 (CA)
[xxiii] Anirudhsinhji Karansinhji Jadeja v. State of Gujarat (1995) 5 SCC 302 : 1995 SCC (Cri) 902
[xxiv] Bhavnagar University v. Palitana Sugar Mill (P) Ltd. (2003) 2 SCC 111; Capt. Sube Singh v. Lt. Governor of Delhi (2004) 6 SCC 440
[xxv] Liversidge v. Anderson 1942 AC 206 : (1941) 3 All ER 338 (HL) 
[xxvi] Clariant International Ltd. v. SEBI, (2004) 8 SCC 524
[xxvii] See Teri Oat Estates (P) Ltd. v. Union Territory, Chandigarh (2004) 2 SCC 130, Union of India v. Rajesh P.U. (2003) 7 SCC 285: 2003 SCC (L&S) 1048  etc
[xxviii] State of Punjab v. Nestle India Ltd. (2004) 6 SCC 465
[xxix] Union of India v. International Trading Co. (2003) 5 SCC 437
[xxx] Associated Provincial Picture Houses Ltd. v. Wednesbury Corpn (1947) 2 All ER 680 : (1948) 1 KB 223 (CA)
[xxxi] Dy. Director of Consolidation v. Deen Bandhu Rai (1964) 4 SCR 560 : AIR 1965 SC 484
[xxxii] Barium Chemicals Ltd. v. Company Law Board 1966 Supp SCR 311 : AIR 1967 SC 295
[xxxiii] Maneka Gandhi v. Union of India (1978) 1 SCC 248
[xxxiv] Shalini Soni v. Union of India (1980) 4 SCC 544 : 1981 SCC (Cri) 38
[xxxv] Rohtas Industries v. S.D. Agarwal (1969) 1 SCC 325
[xxxvi] Council of Civil Service Unions v. Minister for the Civil Service 1985 AC 374 : (1984) 3 All ER 935 (HL) p. 951 a-b
[xxxvii] Gazi Saduddin v. State of Maharashtra (2003) 7 SCC 330 : 2003 SCC (Cri) 1637
[xxxviii] W (An Infant), In re (1971) AC 682: (1971) 2 WLR 1011: (1971) 2 All ER 49 p. 56 g-h
[xxxix] R v Hillingdon LBC ex p Puhlhofer (1986) AC 484: (1986) UKHL 1: (1986) 2 WLR 259: (1986) 1 All ER 467 (HL)
[xl] Bar Council of India v. High Court of Kerala (2004) 6 SCC 311 (paras 49 and 50)
[xli] Union of India v. Tulsiram Patel (1985) 3 SCC 398: 1985 SCC (L&S) 672 (para 101)
[xlii] Chairman, Board of Mining Examination v. Ramjee (1977) 2 SCC 256 : 1977 SCC (L&S) 226
[xliii] Ridge v. Baldwin 1964 AC 40 : (1963) 2 All ER 66 (HL)
[xliv] State of Orissa v. Dr. Binapani Dei (1967) 2 SCR 625 : AIR 1967 SC 1269
[xlv] State of Maharashtra v. Jalgaon Municipal Council (2003) 9 SCC 731
[xlvi] Raghunath Thakur v. State of Bihar (1989) 1 SCC 229
[xlvii] State Govt. Houseless Harijan Employees' Assn. v. State of Karnataka (2001) 1 SCC 610 (paras 27 to 30)
[xlviii] H.C. Narayanappa v. State of Mysore (1960) 3 SCR 742 : AIR 1960 SC 1073
[xlix] S.N. Mukherjee v. Union of India (1990) 4 SCC 594 : 1990 SCC (Cri) 669
[l] Union of India v. Manu Dev Arya (2004) 5 SCC 232 : 2004 SCC (L&S) 769
[li] Union of India v. Kannadapara Sanghatanegala Okkuta (2002) 10 SCC 226
[lii] State of Karnataka v. Dr. Pravin Bhai Thogadia (2004) 4 SCC 684: 2004 SCC (Cri) 1387; Rama Muthuramalingam v. Dy. Supdt. of Police AIR 2005 Mad 1
[liii] Dwarkanath v. ITO (1965) 3 SCR 536 : AIR 1966 SC 81
[liv] Air India Statutory Corpn. v. United Labour Union (1997) 9 SCC 377 : 1997 SCC (L&S) 1344; P.J. Irani v. State of Madras (1962) 2 SCR 169 : AIR 1961 SC 1731
[lv] T.C. Basappa v. T. Nagappa (1955) 1 SCR 250 : AIR 1954 SC 440
[lvi] S. Selvarani v. Commr., Karaikudi Municipality (2005) 1 CTC 81 
[lvii] G.J. Fernandez v. State of Mysore (1967) 3 SCR 636 : AIR 1967 SC 1753; J.R. Raghupathy v. State of A.P. (1988) 4 SCC 364
[lviii] Union of India v. Indo Afghan Agencies Ltd. (1968) 2 SCR 366 : AIR 1968 SC 718
[lix] Motilal Padampat Sugar Mills Co. Ltd. v. State of U.P. (1979) 2 SCC 409
[lx] J.P. Bansal v. State of Rajasthan (2003) 5 SCC 134: 2003 SCC (L&S) 605, paras 25 to 30
[lxi] Amarjit Singh Ahluwalia (Dr.) v. State of Punjab (1975) 3 SCC 503 : 1975 SCC (L&S) 27, para 8; B.N. Nagarajan v. State of Mysore (1966) 3 SCR 682 : AIR 1966 SC 1942; Sant Ram Sharma v. State of Rajasthan (1968) 1 SCR 111 : AIR 1967 SC 1910
[lxii] Ramana Dayaram Shetty v. International Airport Authority of India (1979) 3 SCC 489, para 10
[lxiii] Mafatlal industries v. Union of India, (1997) 5 SCC 536: (1996) II JT 283, earlier discussed at page 489, Note 58
[lxiv] Ninth report, (Specific Relief Act, 1877) 51 (1958)
[lxv] Strachey v. Municipal Board, Cawnpore (1899) 21 ILR All 348; Lahore Municipality v. Munir-ud-Din AIR 1941 Lah 200; Administrator, City of Lahore v. Abdul Majid (1945) ILR Lah 382
[lxvi] Chandulal v Delhi Municipal Corporation AIR 1978 Del 174
[lxvii] Dalpat Kumar v. Prahlad Singh (1992) 1 SCC 719 para 4: AIR 1993 SC 276
[lxviii] Morgan Stanley Mutual Fund v. Kartik Das (1994) 4 SCC 225 paras 37 & 38: (1994) 3 JT 654
[lxix] Hindustan Petroleum Corporation Ltd. v. Sriman Narayan (2002) 5 SCC 760: AIR 2002 SC 2598, paras 7 & 8 and 12
[lxx] Premier Automobiles Ltd. v. Kamleker Shantaram Wadke (1976) 1 SCC 496: AIR 1975 SC 2238, para 29
[lxxi] Dorab Cawasji Warden v. Coomi Sarab Warden (1990) 2 SCC 117, paras 16, 17, 19 and 27: AIR 1990 SC 867
[lxxii] Matro Martin v. Bonus Watch Company (P) Ltd. (2004) 7 SCC 478, para 9: (2004) 7 JT 394
[lxxiii] Krishna v. Anirudha Singh (2005) 12 SCC 389, para 3
[lxxiv] Delhi Municipality v. Suresh Chandra AIR 1976 SC 2621: (1976) 4 SCC 719
[lxxv] Cotton Corporation of India Ltd v.  United Industrial Bank Ltd. (1983) 4 SCC 625: AIR 1983 SC 1272, para 11
[lxxvi] Ramchandra v. Ram Rakhmal AIR 1971 Raj 292
[lxxvii] See Delhi Municipality v. Suresh Chandra AIR 1976 SC 2621 : (1976) 4 SCC 719; Gujarat Bottling Co. Ltd. v. Coca Cola Co. (1995) 5 SCC 545: AIR 1995 SC 2372, para 47; Premji Ratansey Shah v. Uniion of India (1994) 5 SCC 547, para 47 : (1994) 5 JT 585
[lxxviii] D.B. Raval v. Patan Municipality (1967) ILR Guj 18. Also see Gotham Construction Co. Ltd v. Amulya Krishna AIR 1968 Cal 91
[lxxix] Akola Municipality v. Shantarani AIR 1946 Nag 79; Chalisgaon Municipality v. Laxminarayan Mills AIR 1956 Bom 646; Kamakyha Narain Singh v. Union of India AIR 1966 Pat 305; Boldeodas Bajoria v. U. P. Governor AIR 1945 Cal 44
[lxxx] Montogemery Municipality V. Sant Singh AIR 1940 Lah 377
[lxxxi] Eastern Tea Estate v. Silchar Municipality AIR 1967 Ass 1
[lxxxii] Out of the cases mentioned in Note lxxix, only in two, Akola Municipality v. Shantarani AIR 1946 Nag 79 and Boldeodas Bajoria v. U. P. Governor AIR 1945 Cal 44, it was held that alternative legal remedy available should have been exhausted.
[lxxxiii] AIR 1976 SC 888: (1976) 2 SCC 58. Also J. Tiwari v. Jawala Devi Vidya Mandir AIR 1981 SC 1221: (1979) 4 SCC 160
[lxxxiv] Sirsi Municipality v. CKF Tellis AIR 1973 SC 855: (1973) 1 SCC 409
[lxxxv] Raja Ram v. State of Uttar Pradesh AIR 1963 All 449; Kamakhya Narain Singh v. Union of India AIR 1966 Pat 305
[lxxxvi] Ram Chandra v. District Magistrate AIR 1962 All 520
[lxxxvii] Kamakhya Narain Singh v. Union of India AIR 1966 Pat 305; Baldeodas Bajoria v. U.P. Governor AIR 1945 Cal 44
[lxxxviii] Bhagchand v. Secretary of State AIR 1967 PC 176: Sawai Singhai v. Union of India AIR 1966 SC 1068: (1966) 1 SCR 986
[lxxxix] See the fourteenth Report of the Law Commission of India, Vol. II, p. 691. The High Courts give precedence to disposal of writ petitions over other work.
[xc] Bai Shri Vaktuba v. Thakore (1910) 34 ILR Bom 676
[xci] Fisher v. S.S. for India (1889) 26 IA 16; Krishna v. Mahabir AIR 1933 All 488; Subba Rao v. S.S. for India AIR 30 Mad 349; Andhra University v. Lakshmi Manoharam (1951) 1 MLJ 518; Sisir Kumar v. Manorama AIR 1972 Cal 283
[xcii] Sheoparsan Singh v. Ramnandan Pd. AIR 1916 PC 73; Bai Shri Vaktuba v. Thakore (1910) 34 ILR Bom 676; Fahimal Huq v. Jagat Ballav AIR 1923 Pat 475
[xciii] Ramaraghava Reddy v. Seshu Reddy AIR 1967 SC 436: 1966 Supp SCR 270; S.G. Films Exchange v. Brijnath AIR 1975 SC 1810: (1975) 2 SCC 530; Ashok Kumar Shrivasthav v. National Insurance Company Ltd. AIR  1998 SC 2046: (1998) 4 SCC 361
[xciv] Shanta Shamsher v. Kamani AIR 1959 Bom 201
[xcv] Sat Narain Gurlvale v. Hanuman Pd. AIR 1946 Lah 85
[xcvi] Union of India v. Kedereswar AIR 1959 HP 32
[xcvii] Secretary of State v. Subba Rao AIR 1933 Mad 618
[xcviii] Mysore SRT Corporation v. Mirja Khasim AIR 1977 SC 747 at 754: (1977) 2 SCC 457; Vaish Degree College, Shamli v. Lakshmi Narain AIR 1976 SC 888: (1976) 2 SCC 58
[xcix] Ajudhia Nath Dowarka Nath v. Amar Nath Gupta AIR 1961 Punj 352
[c] Mahabir Shamsher v. Lloyds Bank AIR 1968 Cal 371
[ci] Ram Krishna v. Narayana (1916) 39 ILR Mad 80; Andhra University v. Lakshmi (1951) 1 MLJ 518. Also see D.B. Raval v. Paton Municipality (1967) ILR Guj 18; Surendra Nath I.A. Corporation AIR 1966 Cal 272
[cii] Mahabir Shamsher v. Lloyds Bank AIR 1968 Cal 371
[ciii] N.C. Malik v. Bhai Traders (1967) 1 ILR Punj 558
[civ] Bhagat Singh v. Satnam Transport Co. AIR 1961 Punj 278; Annapurna v. Sarat AIR 1942 Cal 394
[cv] Mohd Yunus v. Syed Unnisa AIR 1961 SC 808: (1962) 1 SCR 67
[cvi] Ramsaran v. Gangadevi AIR 1972 SC 2685: (1973) 2 SCC 60, Para 4
[cvii] State of M.P. v. Mangilal Sharma (1998) 2 SCC 510: AIR 1998 SC 743, paras 6 & 10
[cviii] Deo Kuer v. Sheo Pd. AIR 1966 SC 359 (1965) 3 SCR 655. Also Gurdial Singh v. Sunda Hire Purchase Corp. AIR 1970 Pat 7
[cix] Compare Dr. Parmanand v. District Board AIR 1962 Pat 452 with G.S. Dutta v. Union of India AIR 1966 J&K 124; and Fisher v. S.S. for India (1899) 26 IA 16 with Bhagat Singh v. Satnam Transport Co. AIR 1961 Punj 268
[cx] Mysore S.R.T. Corp. v. Mirja Khasim AIR 1977 SC 747 at 754: (1977) 2 SCC 457
[cxi] S.I. Syndicate v. Union of India AIR 1975 SC 460: (1974) 2 SCC 630
[cxii] Raghunath v. Mathura Municipality AIR 1952 All 465
[cxiii] Budhu Singh v. Board of Revenue AIR 1957 All 7I9
[cxiv] Mohd. Ismail v. Patna Municipality AIR 1943 Pat 34
[cxv] Mathewson v. Gordhan Tribedi (1900) 5 CWN 654; Paran v. Parbulg (1878) 3 ILR Cal 612
[cxvi] Bhairabendra v. State of Assam AIR 1953 Ass 162. Also Mulji Haridas v. Ibrahim Rahimtullath AIR 1932 Bom 166; Chotey Lal v. State of Uttar Pradesh AIR 1951 All 228
[cxvii] R.T. Rangachari v. S.S. for India (1936) 64 IA 40. Also cf. Munni Devi v. Gokal Chand 1969 (2) SCC 879
[cxviii] Suwai Singhai v. Union of India AIR 1966 SC 1068; (1966) 1 SCR 968
[cxix] Zamir, the declaratory judgment v. 1962
[cxx] Dyson v. Attomey-General (1919) 1 KB 410 and (1912) 1 Ch 158
[cxxi] Pyx Granite Co. Ltd. v. Ministry of Housing & Local Government (1960) AC 260
[cxxii] Amalgamated Electricity Co. v. Municipal Committee, Ajmer AIR 1969 SC 227: (1969) 1 SCR 430; Public prosecutor v. R. Raju AIR 1972 SC 2504: (1972) 2 SCC 410; Trustees of Bombay Port v. Premier Automobiles, AIR 1974 SC 923: (1974) 4 SCC 710
[cxxiii] State of Gujarat v. Kansara Manilal Bhikaalal (1964) 7 SCR 656: AIR 1964 SC 1893, para 9
[cxxiv] Basappa, supra, 656; S.I. Syndicate v. Union of India AIR 1975 SC 460, 468: (1974) 2 SCC 630
[cxxv] Bombay Housing Board v. Karbhase Naik & Co.AIR 1975 SC 763: (1975) 1 SCC 828
[cxxvi] Union of India v. J.K. Gas Plant AIR 1979 SC 1330. Here the ouster clause barred the suit for "any damage" by anything done under the Act.
[cxxvii] State of Madhya Pradesh v. Sunderlal AIR 1976 MP 175
[cxxviii] Brijraj Singh v. Laxmati Singh (1961) 1 SCR 616: AIR 1961 SC 149, paras 7 & 12
[cxxix] SLA Officer v. T. A. Setty AIR 1959 SC 429: 1959 Supp (1) SCR 404; State v.  Alameluthayammal AIR 1970 Mad 184
[cxxx] Kanakarathamma v. State of Andhra Pradesh AIR 1965 SC 304: (1964) 6 SCR 294; Md. Hasnuddin v. Maharashtra AIR 1979 SC 404: (1979) 2 SCC 572
[cxxxi] State of Mizoram v. Biakchhawna, (1995) 1 SCC 156, paras 7 & 8
[cxxxii] Thakur Das v, State of Madhya Pradesh AIR 1978 SC 1
[cxxxiii] Mysore v. Pandurang P. Naik (1971) 1 Mys LJ 401
[cxxxiv] Gujarat v. C.M. Shah 1974 Cri. LJ 716 (Guj)
[cxxxv] Madhya Pradesh v. Basant Kumar, Jabalpur, LJ 80 (1972)
[cxxxvi] Public Prosecutor v. L. Ramayya 1975 Cri LJ 144 (FB)
[cxxxvii] Sections 35, 37 and 38 of the Advocates Act
[cxxxviii] Chandra Shekhar Soni v. Bar Council of Rajasthan AIR 1983 SC 1012: (1983) 4 SCC 255
[cxxxix] Chandra Shekhar Soni vs Bar Council Of Rajasthan And Ors AIR 1983 SC 1012: 1983 (2) SCALE 384: (1983) 4 SCC 255
[cxl] Chief Controlling Revenue Authority v. Maharashtra Sugar Mills AIR 1950 SC 218, 220: 1950 SCR 536
[cxli] Banarsidas Ahluwalia v. Chief Controlling Authority AIR 1968 SC 497: (1968) 1 SCR 685; P.S. Aggarwal v. Collector of Stamps AIR 1974 Del 155
[cxlii] Union of India v. Sarup Sing AIR 1968 Del 219
[cxliii] Sardamal Ammal v. Chief Controlling Revenue Authority AIR 1960 Mad 21; Sundaram Finance Pvt. Ltd. v. Board of Revenue AIR 1964 Mad 128; Union of India v. Sarup Singh, AIR 1968 Del 219
[cxliv] Union of India v. Sarup Sing, AIR 1968 Del 219
[cxlv] Board of Revenue v. Saraya Sugar Factory AIR 1971 All 70
[cxlvi] Nawaganj Super Mills v. I.T. Commr., Delhi AIR 1972 SC 1684: (1971) 3 SCC 676; C.I.T. v. Khoday Eswara AIR 1972 SC 132: (1971) 3 SCC 555
[cxlvii] Karam Singh Thapar v. C.I.T. AIR 1971 SC 1590: (1972) 4 SCC 124; Karnani Properties Ltd. v. C.I.T. AIR 1972 SC 2315: (1971) 3 SCC 568; C.I.T. v. A.l.D Co. AIR 1972 SC 445: (1972) SCC 447
[cxlviii] Section 256 of the Income Tax Act, 1961 has been omitted by National Tax Tribunal Act, 2005, However, the date or enforcement of the Act was not notified then.
[cxlix] CIT v. Gujarat Heavy Chemicals Ltd. (2002) 10 SCC 250, para I : (2002) 256 ITR 795
[cl] CIT v. Leena Investments (P) Ltd (2001) 10 SCC 234, paras 1 & 2: (2001) 1 SLT 242
[cli] See Order 41 of CPC. Mulla, Code or Civil Procedure. Vol. II, p. 1554 (1967)
[clii] Trustees’ Corporation (India) Ltd. v. C.I.T. AIR 1930 PC 151
[cliii] Commissioner of Income Tax v. Scindia Steamship and Navigation Co. AIR 1961 SC 1633: (1962) 1 SCR 788; E.I. Industries v. I.T. Commissioner AIR 1967 SC 1554: (1967) 3 SCR 356; I.T. Commissioner West Bengal v. Indian Molasses AIR 1970 SC 2067: (1970) 2 SCC 834
[cliv] Commissioner of Income Tax v. Scindia Steamship and Navigation Co. AIR 1961 SC 1633: (1962) 1 SCR 788
[clv] Petland Turkey Red Dye Works Co. Ltd. v. CIT AIR 1963 SC 1484: 1963 Supp (1) SCR 871; New Jahamgir Vakil Mills Ltd. v. CIT AIR 1959 SC 1177: (1960) 1 SCR 249
[clvi] Kilosho Devi Burma v. CIT (1996) 7 SCC 613: AIR 1996 SC 3114, paras 8, 10
[clvii] Union of India v. Addl. Member, Board of Revenue (1975) 36 STC 61 (Cal)
[clviii] Mehta Parikh and Co. v. CIT AIR 1956 SC 554: 1956 SCR 626; Meenakshi Mills Ltd. v. CIT AIR 1957 SC 49: 1956 SCR 691; CIT v. H.S. Chakravarty AIR 1975 SC 15
[clix] Amarchand Sobhachand v. C.I.T. AIR 1971 SC 720: (1970) 1 SCC 595
[clx] Raja Bahadur Kamakshya Narain Singh v. C.I.T. AIR 1971 SC 794: (1969) 3 SCC 791
[clxi] ICI India (P) LId. v. ClT (1972) 3 SCC 370: AIR 1972 SC 1524, para 14
[clxii] K. Ravindra Nathan Nair v. CIT (2001) 1 SCC 135, paras 7 & 8: 2000 Supp (5) SCR 244
[clxiii] LAW COMM. OF INDIA, Twelfth Report (Income-tax Act, 1922) 48 (1958); REPORT OF THE DIRECT TAXES ADMINISTRATION ENQUIRY COMMITTEE 80-81 (1958-59); INTERIM REPORT OF THE DIRECT TAX LAWS COMMITTEE 44 (1977); S.N. Jain. The Customs and Excise Appellate Tribunal, 28 IJPA 11 (1982)
[clxiv] S. Bahadur v. CIT AIR 1972 SC 34: (1971) 3 SCC 364
[clxv] Raja Bahadur Kamakshya Narain Singh v. CIT AIR 1971 SC 794: (1969) 3 SCC 791: (1970) 1 SCC 595
[clxvi] Yusuf Jan Sahib v. I.T.O. AIR 1960 Ker 349
[clxvii] S.P. Prashar v. Vasantsen Dwarkadas AIR 1956 Bom 530
[clxviii] Hardeodas v. I.T.O. AIR 1960 Ass 162. Also T.A. George v. Agricultural I.T.O., 1984 TLR 514
[clxix] See Jyoti Prasad v. l.T.O. AIR 1959 All 456 (where the income tax officer first taxed an association and then he sought to illegally tax the members thereof totally disregarding the statutory provision); Ramiza Bi Saheba v. Income-tax Officer AIR 1960 Mad 357 (where the income of the minor partner was included in the income of the mother who was also a partner in the firm completely contrary to the statutory provision.)
[clxx] Raza Textiles Ltd. Rampur v. I.TO. AIR 1973 SC 1362: (1973) 1 SCC 633
[clxxi] See for instance, Elbridge Watson v. R.K. Das. AIR 1951 Cal 430: Padmanabha v. CIT AIR 1953 TC 296
[clxxii] Raja Jagdambika Pratap Narain Singh v. Central Board of Direct Taxes (1975) 4 SCC 578: AIR 1975 SC 1816, paras 13 & 14
[clxxiii] Trade Tax Officer v. Royal Trading Company (2005) 11 SCC 518, para 1
[clxxiv] ITO v. Mewalal Dwarka Prasad (1989) 2 SCC 279: AIR 1989 SC 1088, para 7
[clxxv] Krishna Gopal v. Dattatraya AIR 1972 MP 125; cj. Rajasthan State Road Transport Corp. v. Kalawati AIR 1977 Raj 236. In Bal Gopal Das v. Mohan Singh AIR 1964 All 504, the tribunal under the Displaced Persons (Debt Adjustment) Act, 1951, was held to be a court.
[clxxvi] Sawatram Ramprashad Mills v. Vishnu Pandorang AIR 1950 Nag 14; H.C.D. Mathur v. E.I. Rly. AIR 1950 All 80; General Manager, Bhilai Steel Project v. Bhutani & Co. 1965 MPLJ (Notes) 73; cf. Rameshwar Lal v. Jogendra Das AIR 1970 Ori 76
[clxxvii] Yeshvant Rao v. Sampat AIR 1978 MP 21
[clxxviii] Abdul Rashid v. Hanuman Oil & Rice Mill AIR 1951 Ass 88; Mohanlal v. Fine Knitting Mills Co. AIR 1960 Bom 387; Rajiyabi v. M.M. & Co. AIR 1970 Bom 278: Shaikh Amir v. Jarder Beg 1979 MPLJ (Notes) 68
[clxxix] Nalakath Sainuddin v.Koorikadan Sulaiman (2002) 6 SCC 1: AIR 2007 SC 2562, para 17
[clxxx] D.L.F. Housing Construction (P.) Ltd. v. Delhi Municipal Corporation AIR 1976 SC 386: (1976) 3 SCC 160
[clxxxi] D.R. Mills v. Commissioner of Civil Supplies AIR 1975 SC 2238 at 2243: (1976) 1 SCC 496
[clxxxii] See Chapter XXIV. Government Contracts. Also, Har Shanker v. Deputy E.&T. Commissioner AIR 1975 SC 1121, 1126: (1975) 1 SCC 737
[clxxxiii] Gurudwara Prabandhak v. Shivrattandeo AIR 1955 SC 576: 55 Punj 1108; Raichand v. Union of India AIR 1964 SC 1268: 1964 (5) SCR 148. The question of adequacy or sufficiency of remedies provided in the Act is of great importance where exclusion is pleaded as a matter of necessary implication; Kamala Mills v. State of Bombay, AIR 1965 SC 1942, p. 1950: (1966) 1 SCR 64; Pabbojan Tea Co. v. D.C., Lakhimpur AIR 1968 SC 271. p. 277: 1968 (1) SCR 260; Dhulabhai v. State of M.P. AIR 1969 SC 78: (1968) 3 SCR 662; Bata Shoe Co. Ltd. v. Jabalpur Corporation AIR 1977 SC 955, pp. 961, 962: (1977) 2 SCC 256; Syed Mohammed Baquir EI Bdroos v. Slate of Gujarat AIR 1981 SC 2016, p. 2019: (1981) 4 SCC 383; State of Andhra Pradesh v. Manjeti Laxmi Kantha Rao, AIR 2000 SC 2220 p. 2221 : (2000) 3 SCC 689; Dhruv Green Fields Ltd. v. Hukum Singh AIR 2002 SC 2841 p. 2844: (2002) 6 SCC 416.
In some cases a statute may provide for a suit in a civil court only after the remedies under the statute are exhausted; see for example State of Madras v. Melamatam AIR 1965 SC 1570, p. 1573: (1966) 2 MLJ (SC) 13; Babu Khan v. Nazim Khan AIR 2001 SC 1740, p. 1745: (2001) 5 SCC 375. The exclusion sometimes is for a limited period within which recourse may be taken to the special remedy and after expiry of that period civil suit can be filed: Mohd. Mahmood v. Tikaram Das AIR 1966 SC 210, pp. 211, 212: 1966 (1) SCR 128 as explained in Nand Kishore v. Ram Kishan AIR 1967 SC 1196, p. 1200: 1967(1) SCR 167
[clxxxiv] Vedagiri Lakshmi Narasimha Swami Temple v. Pattabhirami AIR 1967 SC 781, pp. 785, 786: (1967) 1 SCR 280
[clxxxv] Desika Charyulu v. State of A.P. AIR 1964 SC 806, pp. 811, 816: (1964) 1 LLJ 9
[clxxxvi] United Bank of India v. Debt Recovery Tribunal JT 1999 (2) SC 574 pp. 578, 580: AIR 1999 SC 1381 p. 1385: (1999) 4 SCC 69 [section 2(g) of the Recovery of Debts due to Banks and Financial Institutions Act, 1993 which defines 'debt' construed to be of "the widest amplitude".)
[clxxxvii] K.A. Abdul Jaleel v. T.A. Shahida (2003) 4 SCC 166 p, 170: AIR 2003 SC 2525 p. 2527. In explanation (c) to section7 of the Family Courts Act, 1984 the words suit or proceeding between parties to a marriage with respect to the property of the parties or either of them construed to include disputes between divorced parties.
[clxxxviii] Rajasthan State Road Transport Corporation v. Poonam Pahwa AIR 1997 SC 2951, pp. 2958, 2959: 1997(6) SCC 100
[clxxxix] Secretary of State v. Mask & Co. AIR 1940 PC 105, p. 110; Emperor v. Shibnath Banerjee AIR 1945 PC 156, p. 161; Bombay Province v. Harmusji AIR 1947 PC 200, p. 203; Mohmmad Din v. Imamdin AIR 1948 PC 33, p. 34; Firm Radhakishan v. Ludhiana Municipality AIR 1963 SC 1547, p. 1551: 1964 (2) SCR 273; Firm of Illuri Subbayya Chetty & Sons v. State of A.P. AIR 1964 SC 322, pp. 324, 325: 1964 (1) SCR 752; Laxman v. Stare of Bombay AIR 1964 SC 436, p. 443; Desika Charyulu v. State of A.P. AIR 1964 SC 806: (1964) 1 LLJ 9
[cxc] Anisminic Ltd. v. Foreign Compensation Commission (1969) 1 All ER 208: (1969) 2 AC 147: (1969) 2 WLR 163 (HL); Union of India v. Tarachand Gupta & Bros. AIR 1971 SC 1558: (1971) 1 SCC 486; Bhupendra Singli v. G.K. Umath AIR 1970 MP 91, pp. 95, 98. See further title 2(b) cases of nullity, in Chapter 9: "Statutes Affecting Jurisdiction of Courts", Principles of Statutory Interpretation Justice G.P. Singh, 10th Edn. 2006
[cxci] Ledgard v. Bull ILR 9 All 191, p 203 (PC); B.R. Reddy v. Addl. Custodian of Evacuee Property AIR 1966 SC 1438: 1966 (3) SCR 214
[cxcii] Gaekwar Sarkar of Baroda v. Gandhi Kachra Bai (1903) ILR 27 Bom 344 (PC)
[cxciii] Gaekwar Sarkar of Baroda v. Gandhi Kachra Bai (1903) ILR 27 Bom 344 (PC)
[cxciv] East Fremantle Corporation v. Annois (1900-03) All ER Rep73: 1902 AC 213 (PC)
[cxcv] East Fremantle Corporation v. Annois (1900-03) All ER Rep 73 at 76: 1902 AC 213 (PC)
[cxcvi] HALSBURY'S Laws of England (3rd Edition), Vol. 30, pp. 686, 687. See further Gulf Oil Refining Ltd. (1981) 1 All ER 353 (HL); Wild tree Holds Ltd. v. Harrow London Borough Council, (2000) 3 All ER 289 pp. 294, 295 (HL)
[cxcvii] Radhakrishnan v. Ludhiana Municipality AIR 1963 SC 1547: (1964) 2 SCR 273
[cxcviii] Gaekwar Sarkar of Baroda v. Gandhi Kachra Bai (1903) ILR 27 Bom 344 (PC); East Fremantle Corporation v. Annois (1900-03) All ER Rep 73 at 76: 1902 AC 213 (PC)
[cxcix] Firm Radhakishan v. Ludhiana Municipality, AIR 1963 SC 1547, p. 1551: 1964 (2) SCR 273; referred to in Provincial Government of Madras v. J.S. Basappa AIR 1964 SC 1873: 1964 (5) SCR 517
[cc] Firm Radhakishan v. Ludhiana Municipality AIR 1963 SC 1547, p. 1551: 1964 (2) SCR 273; referred to in Provincial Government of Madras v. J.S. Basappa AIR 1964 SC 1873: 1964 (5) SCR 517
[cci] Poona City Municipal Corporation v. Dattatraya Nagesh Deodhar AIR 1965 SC 555: 1964 (8) SCR 178
[ccii] AIR 1965 SC 555 at 560: (1964) 8 SCR 178. Followed in Firm Surajmal Ballshidhar v. Municipal Board, Ganganagar AIR 1979 SC 246, p. 247: (1979) 1 SCC 303. Same principle applied in sustaining suits for challenging dismissal of a municipal employee in violation of mandatory provisions: Municipal Corporation v. Sri Niyamatullah (1970) 2 SCR 47: AIR 1971 SC 97; J.N. Ganatra v. Morvi Municipality  AIR 1996 SC 2520: 1996 (9) SCC 495.
[cciii] Bharat Kala Bhandar v. Dhamangaon Municipality AIR 1 966 SC 249: (1965) 3 SCR 499. Followed in B.M. Lakhani v. Malkapur Municipality AIR 1970 SC 1002: (1970) 2 SCC 733
[cciv] Kripal Singh v. Municipal Board, Ghaziabad AIR 1968 SC 1416: 1968 (3) SCR 551. See further Khurai Municipality v. Dhannalal AIR 1968 SC 1458: 1969 (1) SCR 166; H.M.M. Ltd. v. Administrator Bangalore City Corporation AIR 1990 SC 47, pp. 52, 53: 1989 (4) SCC 640, (non-compliance with the rules regarding refund of octroi to give effect to statutory exemption does not bar a suit for refund)
[ccv] Firm Radhakishan v. Ludhiana Municipality AIR 1963 SC 1547: (1964) 2 SCR 273
[ccvi] Bata Shoe Co. Ltd. v. Jabalpur Corporation AIR 1977 SC 955, pp. 963, 964: (1977) 2 SCC 256
[ccvii] Raleigh Investment Co. v. G.G. in Council AIR 1947 PC 78, p. 81: 17 IA 50: See further Commr. of Income-tax v. Tribune Trust AIR 1948 PC 102. pp, 106, 107
[ccviii] K.S. Venkatraman & Co. v. State of Madras AIR 1966 SC 1089: 1966 (2) SCR 229
[ccix] Dhulabhai v. State of Madhya Pradesh AIR 1969 SC 78: 1968 (3) SCR 662. See further CIT v. Straw Products AIR 1966 SC 1113: 1966 (2) SCR 881 (Even the High Court in a reference and the Supreme Court in appeal against the order passed in reference cannot decide the question of the validity of the Taxing Act and a statutory order issued under it). State of Tripura v. Province of East Bengal, AIR 1951 SC 23, p. 28: 1551 SCR 1; and State of Bombay v. Jagmohandas AIR 1966 SC 1412: 1966 (2) SCR 279; (a suit to restrain an assessment on the ground that the Taxing Act is ultra vires is not barred); West Bengal Electricity, Regulatory Commission v. CESC Ltd. AIR 2002 SC 3588, p. 3603 (The High Court hearing an appeal under the Electricity Regulatory Commission Act cannot decide the question of validity of a Regulation made under the Act); Central Bank of India v. Vrajlal Kapurchand Gandhi (2003) 6 SCC 573, p. 579 : AIR 2003 SC 3028 (It is settled position in law that a court or tribunal constituted under a statute cannot adjudicate upon the constitutional validity of the statute concerned)
[ccx] Titaghur Paper Mills Co. Ltd. v. State of Orissa AIR 1983 SC 603, p. 607: (1983) 3 SCC 433
[ccxi] Firm of Illuri Subbayya Chetty & Sons v. State of A.P. AIR 1964 SC 322: 1964 (1) SCR 752
[ccxii] Kamala Mills Ltd. v. State of Bombay AIR 1965 SC 1942: 1966 (1) SCR 64. In Provincial Govt. of Madras v. J.S. Basappa, AIR 1964 SC 1873: (1964) 5 SCR 517 where there was only a finality clause but no express bar to challenge all assessment a similar suit was held to be maintainable. Provincial Govt. of Madras v. J.S. Basappa, AIR 1964 SC 1873: (1964) 5 SCR 517 was disapproved in State of Kerala v. Ramaswami AIR 1966 SC 1738: (1966) 3 SCR 582, but the correctness of the disapproval was doubted in Dhulabhai v. State of M.P. AIR 1969 SC 78: 1968 (3) SCR 662
[ccxiii] State of U.P. v. Yadavendra AIR 1966 SC 727, p. 731: 1966 (3) SCR 161
[ccxiv] Mafatlal Industries Ltd. v. Union of India 1996 (9) Scale 457: JT 1996 (11) SC 283: 1997 (5) SCC 536
[ccxv] Mafatlal Industries Ltd. v. Union of India 1997(5) SCC 536: 1996(11) JT 283: 1996(9) Scale 457: 1996(Sup10) SCR 585: 1997(89) ELT 247: 1998(111) STC 467: 1997(1) Supreme 684. See further Union of India v. Solar Pesticides Pvt. Ltd. AIR 2000 C 862: 2000 (2) SCC 705; Commissioner of Central Excise v. Allied Photographic India Ltd. (2004) 4 SCC 34: AIR 2004 SC 2953
Proposition No. (iii) is in accord with the law of European Communities as declared by the EEC Court which is referred in Kleinwort Benson Ltd. v. Birmingham City Council, (1996) 4 All ER 733, p. 740: (1997) QB 380: (1996) 3 WLR 1139 (CA)
[ccxvi] CIT v. Parmeshwari Devi Sultania, JT 1998 (2) SC 413, p. 425: AIR 1998 SC 1276, pp. 1283, 1285: (1998) 3 SCC 481
[ccxvii] CIT v. Parmeshwari Devi Sultania, JT 1998 (2) SC 413, p. 425: AIR 1998 SC 1276, pp. 1283, 1285: (1998) 3 SCC 481
[ccxviii] Secur Industries Ltd. v. Godrej & Boyce Mfg. Co. Ltd. (2004) 3 SCC 447 p.451 para 11: AIR 2004 SC 1766, p.1769 para 11
[ccxix] State of Andhra Pradesh v. N. Venugopal (1964) 3 SCR 742: AIR 1964 SC 33; S.P. Vaithianathan v. K. Shanmuganathan JT 1994 (2) SC 689, p. 693: AIR 1994 SC 1771: (1994) 4 SCC 569
[ccxx] S.P. Vaithianathan v. V.K. Shanmuganathan supra. But registering a false FIR may fall under s. 53
[ccxxi] P.P. Unnikrishnan v. Puttiyottil Alikuty AIR 2000 SC 2952: (2000) 8 SCC 131. For construction of the words "under colour of duty or authority' see, Sumerchand v. Union of India, AIR 1993 SC 2579 : (1994) 1 SCC 64; K.K. Patel v. Stale of Gujarat JT 2000 (7) SC 246: (2000) 6 SCC 195: 2001 SCC (Cri) 200
[ccxxii] Collector of Kamrup v. Kamakhya Ram AIR 1965 SC 1301, p. 1302: 1965 (1) SCR 265; Emporer v. Shibnath Banerji AIR 1945 PC 156, p. 161; Emperor v. Vimalabai Deshpande. AIR 1946 PC 123, p. 127: 1946 Nag 651; but see Bhagwat Prasad v. Secretary of State AIR 1940 PC 82. p.85: 67 IA 197
[ccxxiii] Anisminic Ltd. v. Foreign Compensation Commission (1969) 1 All ER 208 (HL); Rajendra Prakash Sharma v. Gyan Chandra AIR 1980 SC 1206, pp. 1213, 1214: 1980 (3) SCR 207: (1980) 4 SCC 364; Union of India v. Tarachand AIR 1971 SC 1558: 1971 (1) SCC 486; Ramsarup V. Shikharchand AIR 1966 SC 893, pp. 897- 898: (1966) 2 SCR 553; Shivkumar Chadha v. Municipal Corporation, Delhi 1993 (3) SCC 161: (1993) 3 JT 238; Krishanlal v. State of Jammu & Kashmir JT 1994 (2) SC 619 pp. 622, 623: 1994 (4) SCC 422: 1994 SCC (L&S) 885; Dhruv Green Filed Ltd. v. Hukum Singh AIR 2002 SC 2841 p. 2844: (2002) 6 SCC 416; Bhupendra Singh v. G.K. Umath AIR 1970 MP 91, pp. 95-98.
[ccxxiv] Secretary of State v. Mask & Co. AIR 1940 PC 105, p. 110, as explained in Firm of Illuri Subbayya Chetly & Sons v. State of AP AIR 1964 SC 322. p. 326: (1964) 1 SCR 752; which is further referred in Provincial Govt. of Madras v. J.S. Basappa AIR 1964 SC 1873, p. 1877: (1964) 5 SCR 517; Custodian of E.P. v. Jafran Begum AIR 1968 SC 169. p. 174: (1967) 3 SCR 736; Dhulabai v. State of MP AIR 1969 SC 78. p. 86: (1968) 3 SCR 662; Stale of Tamil Nadu v. Ramlinga Swamikal Madam (1985) 4 SCC 10, p. 17: AIR 1986 SC 794; Gurbax Singh v. Financial Commissioner AIR 1991 SC 435. p, 439: 1990 (4) JT 114: 1991 Supp (1) SCC 167
[ccxxv] State of Rajasthan v. Union of India AIR 1977 SC 1361. pp. 1390. 1391. 1401. 1414, 1415: (1977) 4 SCC 599. See further Somvanti v. State of Punjab AIR I963 SC 151 p. 166: (1963) 2 SCR 774
[ccxxvi] Mohammad Din v. Imamdin AIR 1948 PC 33: 74 IA 319
[ccxxvii] Mohammad Din v. Imamdin AIR 1948 PC 33: p. 34 74 IA 319
[ccxxviii] Mohammad Din v. Imamdin AIR 1948 PC 33: p. 34 74 IA 319
[ccxxix] Bombay Province v. Hormusji AIR 1947 PC 200, p. 203: 74 IA 103
[ccxxx] Ramrao v. Jankiram AIR 1963 SC 827: 1963 Supp (1) SCR 322
[ccxxxi] Laxman v. State of Bombay AIR 1964 SC 436: (1964) 1 SCR 200. But see Bhujangrao v. Mulojirao AIR 1952 SC 138: 1952 SCR 402
[ccxxxii] Smith v. East Elloe Rural District Council (1956) 1 All ER 855, pp, 858, 859, 863, 870, 871: 1956 AC 736 (HL)
[ccxxxiii] Somvanti v. State of Punjab AIR 1963 SC 151, p. 166: (1963) 2 SCR 774
[ccxxxiv] Anisminic Ltd. v. Foreign Compensation Commission (1969) 1 All ER 208: (1969) 2 AC 147: (1969) 2 WLR 163 (HL). But in R. v. Secretary for Environment, Ex parte, Ostler  (1976) 3 All ER 90 (CA) it has been held that East Elloe case was not overruled in Anicsminic’s case and is binding on Court of Appeal. The distinguishing features pointed out are: (1) In East Elloe case the Court was permitted to have jurisdiction up to six weeks and the ban operated after this period. In Anisminic case the jurisdiction was ousted from the very beginning; and (2) In East Elloe case the ban operated for challenging an administrative decision whereas in Anisminic case the ban was for challenging a judicial decision of a tribunal. LORD DENNING however, has extra judicially regretted his decision in Ostler's case. He says that the mistake crept in as the judgment was not reserved and was extempore (The discipline of law, p. 108) But Ostler case was followed in R. v. Cornwall County Council, ex parte, Huntington (1994) 1 All ER 694 (CA)
[ccxxxv] Anisminic Ltd. v. Foreign Compensation Commission (1969) 1 All ER 208, pp. 212, 237: (1969) 2 AC 147: (1969) 2 WLR 163 (HL); Arimunissa v. Deputy Custodian, E.P. AIR 1961 SC 362, pp. 370, 371: (1961) 2 SCR 74; Bombay Housing Board v. Karbhase Naik & Co. AIR 1975 SC7 63, pp. 768, 769: (1975) 1 SCC 341
[ccxxxvi] Sundaramier v. State of A.P. AIR 1958 SC 468, p. 482: 1958 SCR 1422. Article 372A of the Constitution has been similarly construed; Union of India v. Prem Kumar Jain AIR 1976 SC 1856, p. 1860: (1976) 3 SCC 743
[ccxxxvii] Sundaramier v. State of A.P., AIR 1958 SC 468, p. 488: 1958 SCR 1422
[ccxxxviii] State of Rajasthan v. Union of India AIR 1977 SC 1361, pp. 1390, 1391, 1401, 1414, 1415: (1977) 4 SCC 599
[ccxxxix] S.R. Bommai v. Union of India IT 1994 (2) SC 215: AIR 1994 SC 1918: (1994) 3 SCC 1. See Summary of the case in A.K. Kaul v. Union of India 1995 (2) Scale 755, p, 764: AIR 1995 SC 1403, p. 1411: (1995) 4 SCC 73
[ccxl] S.R. Bommai v. Union of India IT 1994 (2) SC 215: AIR 1994 SC 1918: (1994) 3 SCC 1. See Summary of the case in A.K. Kaul v. Union of India 1995 (2) Scale 755, p, 764: AIR 1995 SC 1403, p. 1411: (1995) 4 SCC 73
[ccxli] 34. S.R. Bommai v. Union of India, JT 1994 (2) SC 215: AIR 1994 SC 1918: (1994) 3 SCC 1. See Summary of the case in A.K. Kaul v. Union of India, 1995 (2) Scale 755, p. 764: AIR 1995 SC 1403, p. 1411: (1995) 4 SCC 73. For a discussion of the State of Rajasthan and Bommai cases see Gopal Subramanium, Emergency Provisions under the Indian Constitution, Supreme But Not Infallible (2000 Oxford University Press) pp. 147 to 150. In Rameshwar Prasad v. Union of lndia (2005) 7 SCC 625, p. 626 decided on October 7, 2005, a Constitution Bench by majority opinion held that the proclamation dated 23-5-2005 dissolving the Legislative Assembly of Bihar was unconstitutional but the court declined to restore the Legislative Assembly as it stood on the date of proclamation. This case and Bommai case have been also discussed at p. 241 in Chap. 8. For comments on the Bihar case see T.R. Andhyarujina, 'Unsettled out of court', Hindustan Times October 25, 2005.
[ccxlii] Custodian of Evacuee Property v. Jafran Begum, AIR 1968 SC 169, pp. 172, 173: (1967) 3 SCR 736; M. Chayana v. K. Narayana, AIR 1979 SC 1320: (1979) 3 SCC 42; O. Chechulakshamma v. D. Subrahamanya (1980) 3 SCC 130: AIR 1980 SC 133; Mohan Lal v. Kartar Singh, 1995 Supp (4) SCC 684: 1995 (6) Scale 27, p. 35 (This will be so even if the tribunal is required to decide the matter committed to its jurisdiction by a summary enquiry).
[ccxliii] Anwar v. First Additional District Judge, Bulandshahar (1986) 4 SCC 21: AIR 1986 SC 1785
[ccxliv] State of Tamil Nadu v. Ramlinga Samigal Madam (1985) 4 SCC 10, pp. 15, 21 to 23, 25: AIR
1986 SC 794
[ccxlv] State of T.N. v. Ramlinga Samigal Marian (1985) 4 SCC 10: AIR 1986 SC 794

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