New Delhi: The Supreme Court has held that revenue authorities cannot review their own concluded quasi-judicial orders unless such a power is specifically conferred on them by law.
The ruling came in State of West Bengal v. Jai Hind Pvt. Ltd. (2026), where the court examined whether revenue authorities empowered under Section 57A of the West Bengal Estates Acquisition Act, 1953 (WBEA Act) could exercise the power of review.
Section 57A of the Act empowers the State Government to invest an authority with the powers of a civil court under the Code of Civil Procedure (CPC). In exercise of this provision, the State Government had vested revenue authorities with the powers of a civil court under the CPC.
The Supreme Court, however, held that the power of review is not an inherent power of a court or quasi-judicial authority. Such a power must be conferred by law, either expressly or by necessary implication. Quasi-judicial authorities can exercise only those powers that are conferred upon them by the governing statute.
The court observed that the expression “all the powers of the Civil Court” cannot, by itself, be interpreted as conferring the power of review on revenue authorities. Unless there is a specific statutory provision granting such power, the authorities cannot review their earlier orders.
The Supreme Court further emphasised that permitting revenue officers to review their own concluded quasi-judicial orders without an express legislative mandate would raise concerns under the constitutional doctrine of separation of powers, which forms part of the basic structure of the Constitution.
The court noted that although authorities under the WBEA Act perform limited adjudicatory functions, they remain essentially part of the executive branch. They are neither part of the judicial organ nor equipped with the institutional safeguards associated with judicial office, including independence from executive control.
Accordingly, the Supreme Court ruled that the revenue authorities could not exercise the power of review merely because they had been vested with the powers of a civil court under the CPC.
