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Issues: Whether the Commissioner under the Workmen's Compensation Act is a Court and whether an order passed by a single Judge of the High Court in appeal under Section 30 of that Act is a judgment within Clause 15 of the Letters Patent so as to permit a Letters Patent Appeal.
Analysis: The scheme of the Workmen's Compensation Act shows that the Commissioner functions under a special statute creating a distinct forum for speedy and inexpensive adjudication of compensation claims. The Act bars civil court jurisdiction in the matters entrusted to the Commissioner, restricts the subject-matter of claims, and gives the Commissioner limited powers for adjudication under the statute and rules. Though the procedure before the Commissioner has some trappings of a court, those features are not decisive. A Court in the technical sense forms part of the ordinary hierarchy of civil courts and exercises the inherent judicial power of the State, whereas a tribunal created under a special enactment exercises special jurisdiction. The legislative purpose would be defeated if the Commissioner were treated as a Court and the statutory forum were assimilated to the normal civil court hierarchy. The judgment under Section 30 of the Act, therefore, stands on a different footing and does not acquire the character of a Clause 15 judgment merely because the appeal is heard by a single Judge of the High Court.
Conclusion: The Commissioner under the Workmen's Compensation Act is not a Court, and the order of the single Judge in appeal under Section 30 is not a judgment within Clause 15 of the Letters Patent. A Letters Patent Appeal does not lie.
Ratio Decidendi: A forum created by a special statute for a limited adjudicatory purpose is not a Court merely because it has some trappings of a civil court; unless it forms part of the ordinary hierarchy of civil courts and exercises the State's general judicial power, its decision is not a judgment for Letters Patent purposes.