Final statutory orders cannot be reopened by implied review, and discretionary writ relief may be refused for unauthorised reopening.

A statutory vesting order under a complete adjudicatory scheme could not be reviewed in the absence of express legislative authority, because review is not an inherent power and final orders under the Act had attained conclusiveness. The later review orders were therefore without jurisdiction. Although lack of jurisdiction is not cured by waiver, writ relief under article 226 remained discretionary, and petitioners who had allowed the original order to become final and themselves invoked an unauthorised review process were not entitled to certiorari. The High Court's interference was unsustainable and the original statutory orders stood restored in effect.

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Issues: (i) Whether the Competent Officer had any power to review the vesting order in the absence of an express statutory provision. (ii) Whether the writ petitioners were entitled to certiorari under article 226 after having themselves invoked an unauthorised review process and after the original vesting order had attained finality.

Issue (i): Whether the Competent Officer had any power to review the vesting order in the absence of an express statutory provision.

Analysis: The Act conferred a complete scheme for determining claims to composite property. Notices under section 6 were to be followed by claims under section 7, inquiry under section 8, vesting under section 11, and appeal and revision under sections 14 and 15. Section 18 gave finality to orders passed by the Competent Officer or Appellate Officer. The statutory scheme did not provide any general power of review. Review being a creature of statute, an order that had become final under the Act could not be reopened by resort to an inherent or assumed review jurisdiction. The earlier vesting order had therefore become immune from reconsideration once no appeal or revision was filed.

Conclusion: The Competent Officer had no jurisdiction to review the final vesting order, and the later review orders were without authority.

Issue (ii): Whether the writ petitioners were entitled to certiorari under article 226 after having themselves invoked an unauthorised review process and after the original vesting order had attained finality.

Analysis: Even though want of jurisdiction could not be cured by waiver, the extraordinary writ jurisdiction was discretionary. The petitioners had allowed the original order to stand, had not availed the statutory appeal or revision, and had themselves sought an impermissible reopening of the matter to secure a beneficial transfer order. In those circumstances, their conduct disentitled them to discretionary relief. The High Court erred in ignoring the finality of the original order and the petitioners' own unlawful invocation of review machinery.

Conclusion: The writ petitioners were not entitled to certiorari, and the High Court ought not to have granted relief.

Final Conclusion: The statutory orders of the Competent Officer were restored in effect, and the High Court's interference was unsustainable because the writ petitioners had no enforceable basis to reopen a final order through an unavailable review remedy.

Ratio Decidendi: Where a statute creates a complete adjudicatory scheme and makes orders final, review cannot be assumed in the absence of express provision, and discretionary writ relief may be refused to a party whose own conduct shows deliberate resort to an unauthorised reopening of a final order.

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