Statutory appellate remedy and broad appealable orders under recovery law limit Article 227 review and include qualifying interim orders.

A special recovery statute that creates a complete adjudicatory and appellate framework excludes recourse to Article 227 where an efficacious statutory appeal is available. The supervisory jurisdiction of the High Court should not be used to bypass the Act's appellate remedy. The statute's appellate language, using the expressions "any order" and "an order," was construed broadly to include every Tribunal order affecting the rights or liabilities of the parties, including interim orders with such effect. The practical result is that parties must ordinarily proceed through the statutory appeal mechanism, and qualifying interim orders also fall within that appellate scheme.

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Issues: (i) Whether a revision petition under Article 227 of the Constitution of India was maintainable against an order of the Debts Recovery Tribunal when the statute provided an appellate remedy. (ii) Whether the expressions "any order" and "an order" in the recovery statute covered all orders of the Tribunal, including interim orders affecting the rights or liabilities of the parties.

Issue (i): Whether a revision petition under Article 227 of the Constitution of India was maintainable against an order of the Debts Recovery Tribunal when the statute provided an appellate remedy.

Analysis: The recovery statute created a complete mechanism for adjudication and appeal. It conferred jurisdiction on the Tribunal, barred other courts and authorities from exercising jurisdiction in matters covered by the statute, and provided an appeal to the Appellate Tribunal. Where such an efficacious statutory remedy existed, the extraordinary supervisory jurisdiction under Article 227 was not to be used as a substitute for the statutory appeal.

Conclusion: The revision petition under Article 227 was not maintainable and the petitioner was relegated to the statutory appellate remedy.

Issue (ii): Whether the expressions "any order" and "an order" in the recovery statute covered all orders of the Tribunal, including interim orders affecting the rights or liabilities of the parties.

Analysis: The statutory language in the provisions dealing with appellate jurisdiction was construed broadly. The words used were held to extend to every order made by the Tribunal under the Act that affected the rights or liabilities of the parties. On that construction, even interim orders passed in the course of proceedings, if they had such effect, were appealable.

Conclusion: The expressions covered all such orders, including interim orders affecting rights or liabilities.

Final Conclusion: The petition failed because the proper remedy lay in appeal under the special statute, and the Tribunal's orders, including qualifying interim orders, were within the appellate scheme of that Act.

Ratio Decidendi: Where a special statute provides an efficacious appellate remedy and bars ordinary court jurisdiction, supervisory jurisdiction should not be invoked to bypass that remedy, and the statute's appellate language extends to every order affecting the parties' rights or liabilities, including interim orders.

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