Statutory alternative remedy under Section 20 bars Article 227 review against Debts Recovery Tribunal orders absent exceptional grounds.

Where the Recovery of Debts Due to Banks and Financial Institutions Act, 1993 provides an appeal under Section 20 against orders of the Debts Recovery Tribunal, supervisory jurisdiction under Article 227 should ordinarily not be invoked. The statutory scheme creates a complete appellate hierarchy, including procedural rules on limitation and fees, and operates as an effective alternative remedy for recovery disputes. In these circumstances, the High Court should refrain from entertaining a petition under Article 227 unless exceptional grounds such as lack of jurisdiction are shown. The revision petitions were therefore held not maintainable in view of the available statutory appeal.

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Issues: Whether a revision under Article 227 of the Constitution of India was maintainable against an order of the Debts Recovery Tribunal when a statutory appeal lay under Section 20 of the Recovery of Debts Due to Banks and Financial Institutions Act, 1993.

Analysis: Section 20 provides an appeal to the Appellate Tribunal against any order made by the Debts Recovery Tribunal, save only an order made with the consent of parties. The statutory scheme creates a complete hierarchy of appeal, including limitation and fee provisions under the procedural rules, and reflects a special fast-track remedy for recovery disputes. In the presence of this effective alternative remedy, supervisory jurisdiction under Article 227 is not ordinarily to be invoked. The earlier Supreme Court authority relied upon reinforces that the High Court should refrain from entertaining a petition under Article 227 where the Act provides an appellate mechanism.

Conclusion: The revision petitions were not maintainable and were liable to be dismissed in view of the alternative statutory remedy under Section 20.

Ratio Decidendi: Where a statute provides an effective appellate remedy against an order of a specialised tribunal, the High Court should ordinarily decline to exercise jurisdiction under Article 227 in the absence of exceptional grounds such as want of jurisdiction.

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