High Court constitutional review over interlocutory orders survives curtailment of revision, subject to jurisdictional error and grave injustice.

Curtailment of revisional jurisdiction under Section 115 of the Code of Civil Procedure does not abrogate the High Court's constitutional powers under Articles 226 and 227. Interlocutory orders of subordinate civil courts may still be challenged where there is absence or excess of jurisdiction, flagrant disregard of law or procedure, violation of natural justice, or a manifest patent error causing grave injustice. Article 227 superintendence is wider than certiorari, but it must be exercised sparingly and not as a substitute for appeal. Alternative remedy and interlocutory character are relevant self-imposed restraints, not bars to constitutional review.

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Issues: Whether the amendment to Section 115 of the Code of Civil Procedure curtails the High Court's jurisdiction under Articles 226 and 227 over interlocutory orders of subordinate civil courts, and the circumstances in which certiorari or supervisory jurisdiction may be exercised.

Analysis: The amendment to Section 115 of the Code of Civil Procedure restricts revisional jurisdiction, but it does not abrogate the constitutional powers under Articles 226 and 227. Orders of subordinate courts remain amenable to certiorari where there is absence or excess of jurisdiction, flagrant disregard of law or procedure, violation of natural justice, or a manifest patent error causing grave injustice. Supervisory jurisdiction under Article 227 is wider in scope than certiorari, though it is to be exercised sparingly to keep subordinate courts within the bounds of their authority and not as a substitute for appeal. The existence of an alternative remedy and the interlocutory nature of the order are relevant self-imposed restraints, but they do not destroy the constitutional power.

Conclusion: The High Court retains jurisdiction under Articles 226 and 227 despite the curtailment of Section 115, and interlocutory orders of subordinate civil courts may still be challenged where the settled grounds for constitutional interference are made out.

Final Conclusion: The refusal of the High Court to entertain the petition on maintainability was unsustainable, and the matter had to be restored for consideration in accordance with the proper constitutional jurisdiction invoked.

Ratio Decidendi: Curtailment of statutory revision does not affect the High Court's constitutional power of judicial review and superintendence over subordinate courts, which may be invoked only for jurisdictional error, patent illegality, violation of natural justice, or grave injustice, and not as a substitute for appeal.

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