New Delhi: The Supreme Court has held that quasi-judicial Revenue Authorities cannot review their own orders unless the power of review is specifically conferred on them by law.
The ruling came in State of West Bengal v. Jai Hind Pvt. Ltd. (2026), which concerned the scope of powers available to Revenue Authorities under Section 57A of the West Bengal Estates Acquisition Act, 1953.
Section 57A of the Act provides that the State Government may, by order, vest any authority with all the powers of a civil court under the Code of Civil Procedure (CPC).
Exercising this provision, the West Bengal Government had vested Revenue Authorities with the powers of a civil court under the CPC. The issue before the Supreme Court was whether this delegation of powers also enabled the Revenue Authorities to review their own orders.
The Supreme Court held that the power of review is not an inherent power of a court. Such a power must be expressly conferred by law or arise by necessary implication from the statute.
The court further observed that quasi-judicial authorities can exercise only those powers that are expressly granted to them by the statute under which they function. Therefore, merely conferring the powers of a civil court under the CPC does not automatically confer the power of review unless the statute specifically provides for it.
The judgment thus clarified that a statutory authority cannot assume the power of review merely because it has been vested with certain powers of a civil court.
