1. Facts of the Case
A statutory tribunal constituted under a specific Act was empowered to decide disputes strictly within the limits prescribed by that statute. While adjudicating a matter, the tribunal interpreted a provision of the governing statute incorrectly and passed an order affecting the rights of a party. The aggrieved party contended that the tribunal exceeded its lawful authority due to an erroneous interpretation of law. Since the tribunal was of limited jurisdiction, the question arose whether its decision could be corrected through constitutional remedies under Article 226 or 32 of the Constitution of India.
2. Issues in the Case
- Whether an erroneous interpretation of a statute by a tribunal of limited jurisdiction amounts to an error of jurisdiction.
- Whether such an error can be corrected by invoking writ jurisdiction.
- Which writ is appropriate when a tribunal acts beyond its statutory authority due to misinterpretation of law.
3. Legal Principles Covered to Support Case Proceedings and Judgements
Under Indian Administrative Law, tribunals of limited jurisdiction must act strictly within the powers conferred by statute. If a tribunal misinterprets a statutory provision and thereby exceeds its jurisdiction, it commits a jurisdictional error.
The writ of Certiorari is issued by High Courts or the Supreme Court to quash orders passed by inferior courts or tribunals when:
- They act without jurisdiction
- They exceed jurisdiction
- They commit an error of law apparent on the face of the record
Key judicial precedents such as Syed Yakoob v. K.S. Radhakrishnan (1964) establish that an error of law affecting jurisdiction is amenable to certiorari. Unlike an appellate remedy, certiorari corrects legality, not merits.
4. Possible Judgement
The court is likely to hold that the tribunal exceeded its jurisdiction by incorrectly interpreting the statute governing its powers. Since the tribunal’s authority is limited by law, such an erroneous interpretation renders the order invalid. Consequently, the High Court may issue a writ of Certiorari quashing the impugned order. The matter may be remanded for fresh consideration in accordance with the correct interpretation of law or disposed of as per judicial discretion.
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