No statutory power of review under consolidation law made a later reconsideration order ultra vires and without jurisdiction.

Section 42 of the East Punjab Holdings (Consolidation and Prevention of Fragmentation) Act, 1948 conferred revisional power, but not an express power of review. In the absence of statutory authority, a quasi-judicial officer cannot reopen a final order merely because a different view is later formed. The earlier order rejecting the application had attained finality, so the subsequent order purporting to reconsider it was an impermissible review and was ultra vires, illegal, and without jurisdiction.

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Issues: Whether the Director of Consolidation of Holdings had power to review his earlier order passed under section 42 of the East Punjab Holdings (Consolidation and Prevention of Fragmentation) Act, 1948, and whether the later order made on that basis was legally valid.

Analysis: Section 42 conferred revisional power on the State Government to examine the legality or propriety of orders passed under the Act, but the Act contained no express provision authorising review of an order already made under that section. In the absence of such statutory power, a quasi-judicial authority cannot reopen or reconsider a final order merely because it later takes a different view. The earlier order dated 3 April 1958 had finally rejected the application, and the later order dated 29 August 1958 amounted to an impermissible review of that concluded decision.

Conclusion: The Director had no power to review the earlier order, and the subsequent order dated 29 August 1958 was ultra vires, illegal, and without jurisdiction.

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