Special trial regime for coal block prosecutions upheld, with revision and stay powers narrowly confined to prevent delay.
A special trial regime for coal block allocation prosecutions was upheld as a rational classification designed to secure expeditious proceedings. The Court held that litigants had no enforceable right to insist on High Court revision or inherent intervention where the statutory bar on interlocutory challenges applied, and that access to constitutional remedies was not unconstitutionally denied because the forum was only redirected. It further construed the anti-stay scheme narrowly, holding that proceedings could be stayed only within the limited sanction-related failure-of-justice framework and not on broader grounds.
Issues: Whether the appellants had a right to maintain revision petitions or invoke inherent jurisdiction against orders of the Special Judge in the coal block allocation cases; whether the embargo on stay or interruption of proceedings offended Articles 14, 21, 32, 136, 142, 226 and 227 of the Constitution; and whether Section 19(3)(c) of the Prevention of Corruption Act, 1988 permitted a stay of proceedings on grounds other than sanction-related failure of justice.
Issue (i): Whether the appellants had a right to maintain revision petitions or invoke inherent jurisdiction against orders of the Special Judge in the coal block allocation cases.
Analysis: The revisional power under Section 397 of the Code of Criminal Procedure, 1973 is discretionary and does not confer a litigant's right to have every revisable order examined. The bar against revision of interlocutory orders excludes the use of Section 482 to defeat that statutory restriction. An order framing charge or other order that, if set aside, would terminate the proceedings is an intermediate order and may be revisable, but routine challenges to non-substantive interlocutory matters are not. The forum for grievance could be shifted to this Court under Article 136, and the appellants were not denied a remedy, only prevented from pursuing the High Court forum.
Conclusion: The appellants had no enforceable right to insist on revision or inherent intervention in the High Court, and the restriction on that forum was upheld.
Issue (ii): Whether the embargo on stay or interruption of proceedings offended Articles 14, 21, 32, 136, 142, 226 and 227 of the Constitution.
Analysis: The coal block allocation matters were treated as a distinct class because of their scale, public impact, and alleged corruption, so the special procedure was held to rest on a rational and intelligible classification. No substantive procedural safeguard was taken away; only the forum was altered in order to prevent delay and secure an expeditious trial. The Court held that its constitutional powers could be used to shape the forum and procedure in an extraordinary category of cases, while preserving access to this Court and not extinguishing the underlying remedies. The High Court's constitutional jurisdiction was not treated as abolished in the abstract, but its use in this category was held to be impermissible in the interests of the special trial regime.
Conclusion: There was no violation of Articles 14, 21, 32, 136, 142, 226 or 227.
Issue (iii): Whether Section 19(3)(c) of the Prevention of Corruption Act, 1988 permitted a stay of proceedings on grounds other than sanction-related failure of justice.
Analysis: Section 19(3) was construed as creating a tightly controlled scheme: clause (b) permits stay only where an error, omission or irregularity in sanction has caused failure of justice, while clause (c) imposes a blanket prohibition against stay on any other ground and also bars revision in relation to interlocutory orders. The expression "failure of justice" was given a restricted meaning, and the Court rejected the broader reading that would allow routine stays or delay the trial. This interpretation was reinforced by the statutory emphasis on day-to-day trial and by the policy against indirect obstruction of proceedings through revision or collateral challenges.
Conclusion: Section 19(3)(c) did not permit a stay of proceedings on grounds other than sanction-related failure of justice, and the provision was upheld on the restricted interpretation adopted by the Court.
Final Conclusion: The special order governing the coal block allocation trials was sustained, the High Court route was blocked for the categories covered by that order, and the trial regime was required to continue without stay or other impediment except in the limited manner recognized by the statutory scheme.
Ratio Decidendi: Where a special trial regime is created for a distinct class of serious public-interest prosecutions, revisional and inherent jurisdiction may be restricted to prevent delay, and a stay of proceedings can be granted only within the narrow limits expressly permitted by the governing statute.
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