Tribunal review power is limited: final orders cannot be reopened absent statute, except for fraud, with prior notice required.

A Land Reforms Tribunal has no general power to review or reopen its final order unless the statute expressly or by necessary implication confers that authority, because it becomes functus officio after disposal. An exception exists where the earlier order is alleged to have been procured by fraud or material misrepresentation, in which event the tribunal may recall it. Even then, basic fairness requires that the affected party receive prior notice and an opportunity to be heard before the matter is reopened and proceeded with.

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Issues: (i) Whether the Land Reforms Tribunal had jurisdiction to reopen or review its earlier final order in the absence of an express statutory provision, and whether such power could nevertheless be exercised where the earlier order was alleged to have been procured by fraud or misrepresentation. (ii) Whether the petitioner was entitled to notice and opportunity before the Tribunal proceeded to reopen the matter.

Issue (i): Whether the Land Reforms Tribunal had jurisdiction to reopen or review its earlier final order in the absence of an express statutory provision, and whether such power could nevertheless be exercised where the earlier order was alleged to have been procured by fraud or misrepresentation.

Analysis: The statutory scheme did not confer a general power of review on the Tribunal. A tribunal is functus officio after a final order, unless the statute expressly or by necessary implication provides otherwise. However, an exception was recognised where the earlier order was obtained by fraud or material misrepresentation, because the power to recall an order procured by fraud inheres in the adjudicatory authority.

Conclusion: The Tribunal could not reopen or review its final order as a matter of general power, but it could do so if the earlier order had been obtained by fraud or misrepresentation.

Issue (ii): Whether the petitioner was entitled to notice and opportunity before the Tribunal proceeded to reopen the matter.

Analysis: Even where the Tribunal considered reopening the matter on the allegation of fraud, fairness required that the affected declarant be put on notice before the case was actually reopened and proceeded with.

Conclusion: The petitioner was entitled to prior notice and opportunity before reopening of the case.

Final Conclusion: The writ petition was dismissed on the main challenge, but the Tribunal was directed to issue notice before proceeding further, so the petitioner obtained only limited procedural relief.

Ratio Decidendi: In the absence of an express statutory provision, a tribunal cannot review its final order, except that it retains inherent power to recall an order obtained by fraud or material misrepresentation, and any such reopening must conform to basic fairness by giving notice to the affected party.

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