Limits on Jurisdiction of the High Courts under Article 227 | Garment Craft v. Prakash Chand Goel
Limits on Jurisdiction of High Courts under Article 227
Article 227 – Overview
Article 227 empowers the High Courts to exercise supervisory jurisdiction over all courts and tribunals within their territorial jurisdiction.
This jurisdiction is wide but not unlimited.
It allows High Courts to correct errors of jurisdiction, procedural irregularities, or abuses of the process of law.
However, Article 227 is not a substitute for appeal or revision; it cannot be used to re-examine evidence or substitute the High Court’s opinion for that of the lower courts on factual matters.
Key Limits on Article 227 Jurisdiction
Jurisdictional Error: The High Court can interfere only if the lower court or tribunal acted without jurisdiction or exceeded its jurisdiction.
No Reappraisal of Evidence: The High Court does not act as an appellate authority to re-evaluate or reassess evidence.
Finality of Orders: Once an appeal or revision is provided under a statute, the High Court will generally not interfere under Article 227.
Discretionary Power: The High Court’s supervisory jurisdiction is discretionary and should be exercised sparingly to prevent misuse.
Correction of Jurisdictional or Legal Errors: Only those errors that are of a legal nature or amount to a miscarriage of justice can be corrected.
Garment Craft Pvt. Ltd. v. Prakash Chand Goel (2012)
Citation: (2012) 3 SCC 513
Facts
The case involved a dispute where the appellant Garment Craft challenged certain orders passed by the lower forum.
The appellant approached the High Court under Article 227, seeking to quash the orders.
The issue was whether the High Court should interfere under Article 227 when alternative statutory remedies such as appeal or revision were available.
Supreme Court’s Observations
The Supreme Court reiterated that Article 227 jurisdiction is supervisory and not appellate or revisional.
If there is an adequate and efficacious alternative remedy like appeal or revision, the High Court should ordinarily refrain from entertaining a writ petition under Article 227.
Interference under Article 227 is justified only when the orders passed suffer from a patent lack of jurisdiction or miscarriage of justice.
The Court emphasized the need to respect the finality of decisions of the lower courts and tribunals, barring jurisdictional errors.
Conclusion
The Supreme Court dismissed the petition, holding that the High Court’s jurisdiction under Article 227 cannot be used to circumvent the availability of statutory remedies.
It stressed the principle of judicial discipline to ensure High Courts do not overstep their supervisory role.
Summary Table
| Aspect | Details |
|---|---|
| Constitutional Provision | Article 227 |
| Jurisdiction Type | Supervisory (not appellate/revisional) |
| Scope of Jurisdiction | Jurisdictional errors, procedural irregularities |
| Limitations | No reappraisal of evidence; alternative remedies preferred |
| Key Case | Garment Craft Pvt. Ltd. v. Prakash Chand Goel (2012) |
| Supreme Court Holding | Article 227 not to be used to bypass appeals; High Court’s interference limited |
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