Review power must come from statute; a delegate cannot quash a government order without legal authority.

The power of review is not inherent and can be exercised only when expressly conferred by statute or necessarily implied. An order passed by a delegated authority that in substance reopens and nullifies an earlier governmental order amounts to an impermissible review unless the Act authorises that power. Where the State Government itself lacks review jurisdiction, its delegate cannot exercise a wider power than the principal authority. Accordingly, the Government's order remained operative until lawfully set aside, and the delegated Commissioner lacked competence to quash it.

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Issues: Whether the delegated Commissioner had competence to set aside the order of the State Government, given that the power of review is not inherent and must be conferred by law.

Analysis: The order made by the delegate amounted in substance to a review of the earlier order passed by the State Government. A power of review cannot be exercised unless it is expressly conferred by statute or arises by necessary implication. No provision of the Act was shown to confer such power on the Government, and if the Government itself lacked review power, its delegate could not exercise it. Until set aside by a competent authority, the Government's order remained operative and binding on subordinate tribunals.

Conclusion: The delegated Commissioner lacked competence to quash the Government's order, and the impugned order was liable to be set aside.

Ratio Decidendi: The power of review is not inherent and can be exercised only when expressly or impliedly conferred by statute; a delegate cannot exercise a review power that the principal authority does not possess.

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