Supervisory jurisdiction and preliminary jurisdictional objections under a recovery statute remain available without forcing separate trial of issues.

Article 227 supervisory jurisdiction remained available against interlocutory Tribunal orders despite a statutory appellate remedy, because the appeal provision was construed as applying to final orders and not so broadly as to defeat constitutional oversight. In the same recovery framework, the Tribunal was not required to treat jurisdictional objections as a mandatory preliminary issue under Order 14 Rule 2 CPC; that rule is discretionary, and deciding such objections with the remaining issues better served expeditious disposal and avoided piecemeal litigation. The challenge to the interlocutory order therefore failed, and the High Court declined interference.

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Issues: (i) Whether petitions under Article 227 of the Constitution were maintainable against interlocutory orders of the Tribunal in view of the appellate remedy under the statute. (ii) Whether the Tribunal was bound to decide the jurisdictional objection as a preliminary issue under Order 14, Rule 2 of the Code of Civil Procedure before deciding the remaining issues.

Issue (i): Whether petitions under Article 227 of the Constitution were maintainable against interlocutory orders of the Tribunal in view of the appellate remedy under the statute.

Analysis: The statutory scheme barred ordinary civil court jurisdiction in matters assigned to the Tribunal, but expressly preserved the High Court's supervisory jurisdiction under Article 227. The existence of an appellate remedy did not, by itself, exclude constitutional jurisdiction in an appropriate case, particularly where the impugned order was said to be without jurisdiction or otherwise legally infirm. The appellate provision was construed in the context of the Act as relating to final orders, since a construction extending it to every interlocutory order would frustrate the object of speedy debt recovery and create practical impossibility.

Conclusion: The petitions under Article 227 were maintainable in law.

Issue (ii): Whether the Tribunal was bound to decide the jurisdictional objection as a preliminary issue under Order 14, Rule 2 of the Code of Civil Procedure before deciding the remaining issues.

Analysis: The Act was enacted to secure expeditious adjudication and recovery of debts, and its procedure was intended to operate consistently with that object. Order 14, Rule 2 confers only a limited discretion to try a jurisdictional issue first, and even that discretion is not mandatory. The Tribunal was not precluded from following civil procedure where justice required, but in the setting of the Act the better course was to decide the jurisdictional objection with the other issues so as to avoid delay, piecemeal litigation, and remand after appellate intervention. The Tribunal therefore acted within jurisdiction in declining to isolate the jurisdictional point as a preliminary issue.

Conclusion: The Tribunal was not bound to try the jurisdictional objection as a preliminary issue and could decide it along with the other issues.

Final Conclusion: The challenge to the Tribunal's interlocutory order failed, and the High Court declined to interfere, leaving the Tribunal's approach to be decided together with the merits of the proceeding.

Ratio Decidendi: Where a special recovery statute is designed for expeditious disposal, a jurisdictional objection need not be tried separately as a preliminary issue, and the existence of an appellate remedy does not necessarily exclude the High Court's supervisory jurisdiction against an interlocutory order.

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