Non-advocate representation is not a general right; courts may allow appearance only in a specific case, not as routine practice.

A non-advocate power-of-attorney holder has no general right to appear, plead and argue for principals, because Order 3 CPC permits only limited acts by a recognised agent while the Advocates Act reserves legal practice to enrolled advocates. Section 33 bars practice by non-advocates, and Section 32 gives the court only a discretionary, case-specific power to allow appearance in a particular matter. A blanket authorisation for present and future litigation amounts in substance to practising law without enrolment, and no special grounds were shown to justify an exception. The request for permission was therefore correctly rejected.

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Issues: Whether a non-advocate power-of-attorney holder can be permitted to appear, plead and argue for the principals in court under the Advocates Act and the Code of Civil Procedure.

Analysis: The statutory scheme distinguishes between the limited acts that a recognised agent may perform under Order 3 of the Code of Civil Procedure, 1908, and the right to practice law, which is governed by the Advocates Act, 1961. Section 33 of the Advocates Act prohibits practice by anyone who is not enrolled as an advocate, while Section 32 confers only a discretionary power on the court to permit a non-advocate to appear in a particular case. The power to permit appearance does not extend to a general authority to plead and argue as an advocate. The requested authorization was not confined to any special circumstance of a single case but was framed as a continuing arrangement for all present and future litigation, which amounted in substance to practicing law without enrolment. No special grounds were shown to justify an exception under Section 32.

Conclusion: A non-advocate power-of-attorney holder cannot claim a right to plead and argue as of course, and the application for such permission was rightly rejected.

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