Quasi-judicial rent control order cannot be reviewed or cancelled without express statutory power; void revision restored no rights.

An allotment order under the rent control statute was treated as quasi-judicial because the officer had to decide contested questions affecting the parties' rights, including applicability of the Act, liability to eviction, and proper allotment. Such an order could not be reviewed or cancelled by the same authority unless the statute expressly conferred that power, and no such power existed. The later cancellation and subletting order was therefore without jurisdiction and void. The State Government, in revision, could not restore or validate a void order or exercise powers not available under the Act. The challenge to the quashing of the State Government's action failed.

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Issues: Whether the Rent Control and Eviction Officer had jurisdiction to review and cancel his earlier allotment order, and whether the State Government could restore the later order passed without jurisdiction.

Analysis: The accommodation was held to be governed by the Act. In the circumstances existing when the first order was made, the Rent Control and Eviction Officer had to determine contested questions affecting the rights of the parties, including applicability of the Act, liability to eviction, and the proper allotment. The order under Section 7(2) was therefore quasi-judicial in character. A quasi-judicial order cannot be reviewed or cancelled by the authority making it unless the statute expressly confers such power, and no such power was provided. The subsequent order purporting to cancel the first order and directing subletting was accordingly without jurisdiction and void. The State Government, in revision, could not restore a void order or itself exercise powers not available under the Act. The appellant also could not obtain relief when it had submitted to the operative order and had no enforceable right under the invalid sub-lease.

Conclusion: The review and cancellation order was void, the State Government's restoration order was without jurisdiction, and the challenge to the quashing of that order failed.

Final Conclusion: The appeal was dismissed and the order of the learned single Judge quashing the State Government's action was upheld.

Ratio Decidendi: A quasi-judicial order passed under a rent control statute cannot be reviewed or cancelled by the same authority in the absence of express statutory power, and a revisional authority cannot restore or validate an order passed without jurisdiction.

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