court India Law News

SC: Revenue authorities cannot review own orders without specific statutory power

New Delhi: The Supreme Court has held that revenue authorities cannot review their own quasi-judicial orders unless such power is specifically conferred by law.

The ruling came in State of West Bengal v. Jai Hind Pvt Ltd (2026), concerning Section 57A of the West Bengal Estates Acquisition Act, 1953. The provision allows the state government to confer on authorities the powers of a civil court under the Code of Civil Procedure (CPC).

The court held that the power of review is not an inherent power of a court and must be specifically granted by statute, either expressly or by necessary implication. Quasi-judicial authorities can exercise only those powers that are conferred on them by law.

It also ruled that the expression “all the powers of the Civil Court” does not by itself confer the power of review on revenue authorities.

The court further observed that allowing an executive authority to review its own concluded quasi-judicial order without an express legislative mandate would raise concerns under the constitutional principle of separation of powers, which forms part of the basic structure of the Constitution.

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