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Issues: Whether the Civil Courts had jurisdiction to entertain a suit challenging a notification fixing reduced rent under the Reduction of Rent Act, and whether the notification was protected by the statutory bar on judicial review.
Analysis: The statutory scheme empowered the Special Officer to determine fair and equitable rent rates on the basis of relevant material and required the Government to act on such recommendations. The bar on questioning orders under the Act applied only to orders made in conformity with the Act. The determination in question was founded solely on an irrelevant settlement-register entry relating to another village, without any proper factual inquiry into the suit village. A determination based on no evidence was treated as contrary to the fundamental principles of judicial procedure and as not being an order made within the authority of the Act. In such a situation, the exclusion of civil court jurisdiction could not operate.
Conclusion: The Civil Courts were held to have jurisdiction, and the notification reducing rent was held to be outside the protection of the statutory bar and liable to be struck down.
Final Conclusion: The appeals succeeded, the impugned rent-reduction notification was invalidated, and the parties were left to proceed in accordance with law.
Ratio Decidendi: A statutory bar on civil court jurisdiction does not protect an order that is made without relevant evidence or in breach of the Act's procedural requirements, because such an order is not one validly made under the statute.
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