Natural justice bars an authority from hearing an appeal against its own prior order absent express statutory permission.

An appellate authority cannot hear an appeal against its own earlier order unless the statute expressly permits that course, because appeal is distinct from review and self-adjudication offends natural justice. Applying the principle that no person may be a judge in his own cause, the court held that the Commissioner's participation in deciding the appeal against his prior order vitiated the appellate process. The appellate order was therefore quashed and the matter remanded for fresh decision by another competent officer.

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Issues: Whether an appellate authority can hear and decide an appeal against its own order passed earlier in another capacity under the Indian Stamp Act, 1899.

Analysis: The right of appeal is a statutory right intended to secure review of an inferior authority's decision by a superior authority. An appeal is conceptually distinct from a review, and permitting the same officer to sit in appeal over his own earlier order would reduce the appellate process into a self-review and render the remedy illusory. The principle of natural justice that no person should be a judge in his own cause applies not only where a decision-maker is personally interested, but also where the very order made by him is under challenge in appeal. The settled practice and authority support the view that, unless the statute expressly permits it, a judge or authority should not participate in the determination of an appeal against his own decision.

Conclusion: The appellate order was vitiated because the Commissioner decided the appeal against his own earlier order, contrary to natural justice; the writ petition was allowed, the appellate order was quashed, and the matter was remanded for fresh decision by another officer.

Ratio Decidendi: An appellate authority cannot legally adjudicate an appeal against its own prior order unless the statute expressly authorises such course, as doing so violates the principle of nemo judex in causa sua.

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