Special statute with complete appellate and revisional scheme excludes High Court interference under inherent criminal jurisdiction.

A special statute that creates its own complete scheme for trial, appeal and revision excludes resort to the High Court's inherent revisional jurisdiction. The Mirzapur Stone Mahal Act, 1886 provided trial by the Assistant Collector and specific appellate and revisional remedies within the statutory hierarchy, while the Criminal Procedure Code applied only for search warrants. On that footing, orders passed under the Act were not open to interference under Section 561-A of the Criminal Procedure Code, 1898, because the statute did not contemplate additional High Court supervision outside its self-contained mechanism.

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Issues: Whether the High Court could interfere under its inherent revisional power with orders passed by the Sub-Divisional Officer under the Mirzapur Stone Mahal Act, 1886, when that Act itself provided a complete scheme of trial, appeal, and revision.

Analysis: The proceeding arose under a special enactment that regulated the entire procedure for offences under it. The Act contemplated trial by the Assistant Collector, not by a Magistrate, and expressly provided appellate and revisional remedies to the Collector, the Commissioner, and in some cases the Local Government. Criminal Procedure Code provisions were made applicable only for search warrants. Since the Act itself created a self-contained remedy structure and did not provide for High Court interference, the orders complained of were not amenable to revision by the High Court under Section 561-A of the Code of Criminal Procedure, 1898.

Conclusion: The High Court had no jurisdiction to interfere with the orders passed by the Sub-Divisional Officer, and the references were rejected.

Final Conclusion: The decision affirms that where a special statute provides its own complete appellate and revisional mechanism, the High Court will not assume supervisory interference outside that scheme.

Ratio Decidendi: A special enactment containing its own complete procedure for trial and its own appellate or revisional remedies excludes High Court interference under inherent criminal jurisdiction unless the statute itself so provides.

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