Section 100-A bars Letters Patent appeals after a single Judge decision, including in special enactment matters.

Section 100-A of the Code of Civil Procedure, 1908, as substituted, creates a clear non-obstante bar on any further appeal where an original or appellate decree or order has been heard and decided by a single Judge of a High Court. That bar extends to Letters Patent appeals and also to appeals under special enactments or other instruments having force of law, unless the governing statute expressly preserves a further appeal. The Letters Patent remains intact, but the statutory prohibition displaces the right to prefer another intra-court appeal after a single-Judge decision.

---

---

Issues: Whether the right of appeal under the Letters Patent survives after the insertion of Section 100-A of the Code of Civil Procedure, 1908 in respect of matters arising under special enactments or other instruments having force of law.

Analysis: Section 100-A, as substituted, contains a clear non-obstante clause and provides that where an appeal from an original or appellate decree or order is heard and decided by a single Judge of a High Court, no further appeal shall lie. The language is wide enough to cover appeals under the Letters Patent as well as appeals provided under special enactments. The provision is a legislative declaration and, despite the Letters Patent remaining intact, the right to prefer a further appeal is taken away when the matter has been heard and decided by a single Judge. The reasoning relied upon in earlier decisions on the continuing availability of Letters Patent appeals did not apply where the statute expressly barred further appeal.

Conclusion: The right of appeal under the Letters Patent is barred by Section 100-A of the Code of Civil Procedure, 1908 even in matters arising under special enactments or other instruments having force of law.

Final Conclusion: The reference was answered against the appellant, and the letters patent appeal was held to be not maintainable.

Ratio Decidendi: When Section 100-A of the Code of Civil Procedure, 1908 expressly bars any further appeal from a judgment, decree, or order of a single Judge, the bar overrides the Letters Patent and extends to appeals under special enactments unless the statute clearly preserves such further appeal.

---