Supervisory and inherent jurisdiction cannot override a statutory bar against interference with interlocutory orders.

Supervisory jurisdiction under Article 227 and inherent jurisdiction under Section 482 cannot be used to bypass an express statutory bar on appeal or revision against an interlocutory order. Where the special enactment preserves challenge to such an order in the statutory appeal against the final judgment, the High Court should not interfere unless there is demonstrated abuse of process or immediate miscarriage of justice. The article notes that the interlocutory grievance could be raised in the pending statutory appeal without prejudice, so the impugned interference was not justified and the statutory appellate scheme had to be respected.

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Issues: Whether the High Court could invoke its supervisory or inherent jurisdiction to interfere with an interlocutory order when the special statute provided an express bar against appeal or revision and preserved the challenge only in the statutory appeal against the final judgment.

Analysis: The order of the Special Judge was interlocutory. The special statute barred appeal or revision from such an order and required the statutory appeal to be heard by a Bench of two Judges. The High Court did not state that it was acting under Article 227, and in any event that power could not be used sparingly as a substitute for an appeal or to circumvent the statutory scheme. The inherent power under Section 482 could not be exercised where a specific remedy existed under the special enactment and no abuse of process or immediate miscarriage of justice was shown. Since the evidence had already been recorded, any error in the interlocutory order could be tested in the pending statutory appeal without prejudice to the respondents.

Conclusion: The High Court was not justified in interfering with the interlocutory order, and the impugned order was liable to be set aside.

Final Conclusion: The statutory appellate route under the special enactment had to be respected, and the parties were left free to agitate all questions before the Division Bench hearing the pending appeal.

Ratio Decidendi: Supervisory jurisdiction under Article 227 and inherent jurisdiction under Section 482 cannot be used to override an express statutory bar or to interfere with an interlocutory order where the grievance can be adequately raised in the statutory appeal.

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