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Issues: Whether a revenue officer invested with the powers of a civil court under the West Bengal Estates Acquisition Act, 1954 could invoke inherent powers under Section 151 of the Code of Civil Procedure, 1908 to revise a finally published record of rights despite the specific revisional power contained in Section 44(2-a) of the Act, and whether the notice and proceedings initiated on that basis were valid.
Analysis: Section 151 preserves the inherent powers of a civil court, but those powers are to be exercised only where no specific statutory provision governs the subject. The Act itself contained an express provision enabling revision of a finally published record of rights under Section 44(2-a). The existence of that specific machinery meant that recourse to inherent powers was not justified. Although the officer had been invested with civil court powers under the Act, such investment did not authorise bypassing the statutory scheme. A notice issued in aid of proceedings founded on an assumed power under Section 151, therefore, could not sustain jurisdiction where the proceedings themselves were incompetent.
Conclusion: The officer had no jurisdiction to commence or continue the proceedings under Section 151, and the impugned notice was bad and liable to be quashed.
Ratio Decidendi: Inherent powers under Section 151 of the Code of Civil Procedure, 1908 cannot be invoked where the governing statute provides a specific power and procedure for the relief sought; an authority invested with civil court powers must act within that statutory framework.