Administration of justice includes power to regulate court jurisdiction; State amendment transferring first appeals was upheld.

The expression "administration of justice" in the State List was construed broadly to include power to define, alter, regulate, or diminish court jurisdiction, so the State Legislature could transfer first appeals from the High Court to the District Judge. Entry 78 of the Union List was held to concern only the constitution and organisation of High Courts, not an exclusive Parliamentary power over their general jurisdiction, and the amendments were therefore within State competence. The Court also rejected claims based on repugnancy, Letters Patent supremacy, and impairment of Article 235 control, holding that the High Court's supervisory scheme remained intact. The impugned amendment Acts were upheld as valid.

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Issues: (i) Whether the State Legislature had competence to amend the appellate jurisdiction of the High Court and related court structure under the constitutional entries dealing with administration of justice and the constitution and organisation of courts. (ii) Whether the impugned amendment Acts were invalid because the subject fell exclusively within Parliament's legislative field or because they impaired the High Court's constitutional control over subordinate courts.

Issue (i): Whether the State Legislature had competence to amend the appellate jurisdiction of the High Court and related court structure under the constitutional entries dealing with administration of justice and the constitution and organisation of courts.

Analysis: The expression "administration of justice" in Entry 3 of List II was treated as a distinct and wide legislative topic, capable of including the power to define, enlarge, alter, amend, diminish, or regulate the jurisdiction of courts. The omission of "jurisdiction and powers" from Entry 78 of List I was held to be significant, because that entry was confined to the constitution and organisation of High Courts and did not itself confer exclusive Parliamentary power over their general jurisdiction. The scheme of the Seventh Schedule, read with the constitutional provisions relating to High Courts, showed that the State Legislature could legislate on the jurisdiction and powers of courts in matters within its field, subject to express constitutional limits and Parliament's special powers under Entry 95 of List I. The impugned amendments transferring first appeals from the High Court to the District Judge were therefore within the legislative field of the State.

Conclusion: The State Legislature had legislative competence to enact the impugned amendments, and the challenge to their vires on this ground failed.

Issue (ii): Whether the impugned amendment Acts were invalid because the subject fell exclusively within Parliament's legislative field or because they impaired the High Court's constitutional control over subordinate courts.

Analysis: The Court rejected the submission that the High Court's jurisdiction under the Letters Patent or earlier laws was frozen beyond legislative alteration. It held that the Punjab Courts Act continued to be a valid law and that the amendments made to it by the State Legislature did not attract repugnancy, since the State was acting within its competence. The Court also held that the impugned changes did not extinguish the High Court's constitutional control over subordinate courts under Article 235, because the High Court retained appellate supervision through the statutory scheme, including second appeal after the first appellate forum.

Conclusion: The contention based on exclusive Parliamentary power, repugnancy, Letters Patent supremacy, and impairment of judicial control was rejected.

Final Conclusion: The impugned amendment Acts were upheld as valid exercises of State legislative power, and the miscellaneous petition challenging their vires failed.

Ratio Decidendi: "Administration of justice" in the State List authorises the State Legislature to regulate the jurisdiction and powers of courts, including the High Court, while Entry 78 of List I is confined to the constitution and organisation of High Courts and does not by itself confer exclusive power over their general jurisdiction.

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