Supervisory jurisdiction and unauthorised counsel concessions cannot expand the dispute or bind substantive rights without specific client authority.

In supervisory jurisdiction under Articles 226 and 227, the Court must confine itself to the subject matter of the challenge and cannot issue incidental directions on matters outside the lis. A concession by counsel does not bind a cooperative society or its members on substantive rights unless specifically authorised by the client, and authority cannot be presumed from mere appearance. The impugned directions based on the unauthorised concession were therefore set aside, while the findings upholding the expulsion from membership remained undisturbed.

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Issues: (i) Whether, in proceedings invoking Articles 226 and 227 of the Constitution of India, the Court could travel beyond the subject matter of the challenge and issue incidental directions unrelated to the validity of the impugned administrative orders. (ii) Whether a concession made by counsel, without express authority from the party, could bind the cooperative society and its members.

Issue (i): Whether, in proceedings invoking Articles 226 and 227 of the Constitution of India, the Court could travel beyond the subject matter of the challenge and issue incidental directions unrelated to the validity of the impugned administrative orders.

Analysis: The petitions, in substance, sought supervisory review of the orders passed by the statutory authorities confirming expulsion from membership. Once the Court found that the expulsion was justified and the authorities had committed no error, it was required to confine itself to that controversy. In supervisory jurisdiction, the Court cannot expand the scope of the proceedings to grant directions on matters not forming part of the lis, as that would exceed the permissible ambit of Article 227.

Conclusion: The directions issued beyond the subject matter of the writ petitions were not sustainable.

Issue (ii): Whether a concession made by counsel, without express authority from the party, could bind the cooperative society and its members.

Analysis: An advocate acts as an agent only within the scope of authority conferred by the client. The governing professional rules require advocates to act on client instructions and prohibit compromise or concession without proper and specific authorization. A concession that affects substantive rights cannot be presumed from mere appearance in Court, and a statement made without authority does not bind the client, especially where it concerns matters outside the issue before the Court.

Conclusion: The alleged concession did not bind the appellant-society or its members.

Final Conclusion: The appeals succeeded, and the impugned directions made on the basis of the unauthorized concession were set aside while the findings upholding expulsion remained undisturbed.

Ratio Decidendi: In supervisory jurisdiction, the Court must remain confined to the subject matter of challenge, and a counsel's concession cannot bind the client on substantive matters unless specifically authorized by the client.

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