Review power under rent control law was unavailable because the special statute contained no such provision.

Review was unavailable under the Madras Buildings (Lease and Rent Control) Act, 1949 because neither the Act nor the rules conferred a review power. The court treated review as a statutory power, not an inherent one, and held that it could be exercised only when expressly provided. It further held that the Code of Civil Procedure did not generally apply to proceedings under this self-contained special enactment, and that Section 141 did not extend the entire Code, including Order 47 Rule 1, to such proceedings. The review application therefore did not lie.

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Issues: Whether an application for review lay under the Madras Buildings (Lease and Rent Control) Act, 1949, either on the footing of inherent power or under Order 47, Rule 1 and Section 141 of the Code of Civil Procedure, 1908.

Analysis: The Act and the rules framed thereunder contained no provision for review. Review is not an inherent power of a judicial officer and can be exercised only when conferred by statute. The Act was treated as a self-contained special enactment, and the provisions of the Code of Civil Procedure were held not to apply generally to proceedings under it. Section 141 of the Code was held not to extend the entire Code, including the power of review, to such special proceedings where the statute and procedure were self-contained.

Conclusion: The application for review did not lie.

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