Revisional jurisdiction over special-statute tribunals depends on civil-court status, statutory exclusion, and absence of jurisdictional error.

A tribunal or authority under a special statute that records evidence and determines civil rights may be treated as a civil court subordinate to the High Court for revision under Section 115 of the Civil Procedure Code, unless the statute clearly excludes that jurisdiction. The exclusion of ordinary civil suits does not by itself bar revisional supervision, and Article 227 supports the High Court's superintendence over such bodies. An order restoring proceedings for sufficient cause is not to be disturbed in revision unless it is shown to suffer from jurisdictional error, illegality, or material irregularity.

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Issues: (i) Whether the Collector and the District Collector exercising jurisdiction under the Madras Hereditary Village Offices Act are courts subordinate to the High Court so as to attract revisional jurisdiction under Section 115 of the Civil Procedure Code. (ii) Whether the District Collector's order restoring the suit for hearing suffered from any jurisdictional error, illegality, or material irregularity warranting interference in revision.

Issue (i): Whether the Collector and the District Collector exercising jurisdiction under the Madras Hereditary Village Offices Act are courts subordinate to the High Court so as to attract revisional jurisdiction under Section 115 of the Civil Procedure Code.

Analysis: The proceedings under Section 13(1) of the Act involved determination of civil rights concerning a claim to office and its emoluments. A body empowered to record evidence and decide disputes of a civil nature is a court for the purposes of the Code. Courts constituted under a special statute do not cease to be civil courts merely because their jurisdiction is special or limited, and the exclusion in Section 21 of the Act bars ordinary civil suits but does not exclude the High Court's revisional power. The constitutional power of superintendence under Article 227 also reinforces the subordinate status of such tribunals within the High Court's territorial jurisdiction.

Conclusion: The Collector and the District Collector were courts subordinate to the High Court, and the revision under Section 115 of the Civil Procedure Code was maintainable.

Issue (ii): Whether the District Collector's order restoring the suit for hearing suffered from any jurisdictional error, illegality, or material irregularity warranting interference in revision.

Analysis: The District Collector found sufficient cause for the plaintiff's absence on the date fixed for hearing and held that the dismissal for default should be set aside. No material was shown to establish that this conclusion was outside jurisdiction, legally impermissible, or vitiated by material irregularity. The revisional court does not interfere merely because another view is possible on the facts.

Conclusion: The District Collector's order did not warrant interference in revision.

Final Conclusion: The preliminary objection failed, the restoration order was upheld, and the revision petition was dismissed with no order as to costs.

Ratio Decidendi: A tribunal or authority deciding civil rights under a special statute is a civil court subordinate to the High Court for the purposes of revision, unless the statute clearly excludes such jurisdiction; an order restoring proceedings for sufficient cause will not be interfered with absent jurisdictional error or material irregularity.

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