Limited tribunal powers in pre-emption proceedings do not include civil court injunction jurisdiction under the procedural code.

In pre-emption proceedings under the West Bengal Land Reforms Act, 1956, a Revenue Officer has only the limited powers expressly or by necessary implication conferred by the statute. Section 57 permits limited civil court powers for enforcing attendance, production of documents, and execution of orders, but it does not convert the Revenue Officer into a civil court or confer inherent powers under the Code of Civil Procedure. A quasi-judicial tribunal cannot assume civil court powers, including injunction powers, unless the statute clearly provides for them. Accordingly, the Revenue Officer has no jurisdiction to grant ad interim injunction under Section 151 or Order 39 of the CPC.

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Issues: Whether the Revenue Officer, while dealing with pre-emption proceedings under the West Bengal Land Reforms Act, 1956, had jurisdiction to grant ad interim injunction under Section 151 or Order 39 of the Code of Civil Procedure, or otherwise.

Analysis: The pre-emption provisions in Sections 8, 9 and 10 of the West Bengal Land Reforms Act, 1956, read with Section 57, conferred only the specific powers mentioned in the statute. Section 57 enabled the Revenue Officer to exercise certain civil court powers for limited purposes, namely enforcing attendance, production of records or documents, and enforcing or executing orders, but it did not make the Revenue Officer a civil court or confer all powers of a civil court. A quasi-judicial tribunal cannot claim the inherent powers of a civil court unless such powers are expressly or by necessary implication conferred by statute. The power to correct one's own mistakes or to adopt necessary procedure does not create a new jurisdiction to grant injunctions.

Conclusion: The Revenue Officer had no jurisdiction to grant injunction under Section 151 or Order 39 of the Code of Civil Procedure, or otherwise, and the injunction orders were without jurisdiction.

Ratio Decidendi: A quasi-judicial tribunal possesses only those powers expressly or impliedly conferred by the statute creating it, and inherent powers of a civil court cannot be assumed so as to create a jurisdiction to grant injunction unless the statute so provides.

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