Article 227 supervisory power overrides statutory finality where Panchayati Adalat proceedings suffer jurisdictional error and mandatory procedure breaches.

Article 227 was treated as a broad supervisory power enabling the High Court to control judicial and administrative functioning of courts and tribunals within its territory, and a statutory finality clause could not exclude review for jurisdictional error, patent mistake, abuse of jurisdiction, or miscarriage of justice. In the Panchayati Adalat context, unauthorised intervention by the Sarpanch, irregular constitution of the bench, and non-compliance with mandatory procedure, including failure to explain the charge, were treated as jurisdictional defects that invalidated the proceedings. On the offence issue, affray required a bilateral public fight, and one-sided aggression without mutual combat was insufficient.

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Issues: (i) whether Article 227 of the Constitution of India empowered the High Court to interfere with judicial orders of a Panchayati Adalat despite the finality clause in the U.P. Panchayat Raj Act, 1947; (ii) whether the conviction was vitiated by the participation of the Sarpanch, absence of mandatory procedure, and irregular constitution and functioning of the bench; (iii) whether the facts alleged disclosed the offence of affray under the Penal Code.

Issue (i): whether Article 227 of the Constitution of India empowered the High Court to interfere with judicial orders of a Panchayati Adalat despite the finality clause in the U.P. Panchayat Raj Act, 1947

Analysis: Article 227 was treated as conferring a wide supervisory jurisdiction over all courts and tribunals within the High Court's territory. The omission in the Constitution of the earlier statutory restriction confining superintendence to courts subject to appellate jurisdiction was viewed as deliberate. The finality clause in the Panchayat Raj Act could not cut down a constitutional power, and the High Court could intervene where there was jurisdictional excess, abuse of jurisdiction, patent error, or miscarriage of justice.

Conclusion: The preliminary objection to maintainability was rightly overruled, and the High Court had power to examine the matter under Article 227.

Issue (ii): whether the conviction was vitiated by the participation of the Sarpanch, absence of mandatory procedure, and irregular constitution and functioning of the bench

Analysis: Once a bench had been constituted, the Sarpanch had no authority to take over the proceedings unless he was a member of that bench. The record showed unauthorised intervention by the Sarpanch, appointment of a commission by him, lack of signatures of all required panches, and non-compliance with the mandatory requirement of explaining the charge. These defects showed that the proceedings were not conducted in the manner required by the Act and Rules and amounted to action beyond jurisdiction.

Conclusion: The conviction and the proceedings of the Panchayati Adalat were invalid and liable to be quashed.

Issue (iii): whether the facts alleged disclosed the offence of affray under the Penal Code

Analysis: Affray requires a fight in a public place, and a fight is bilateral in character. On the complaint and evidence, the accused had only rushed to the scene and no mutual fighting or exchange of blows was shown. A one-sided aggression, with the other side remaining passive, does not constitute affray.

Conclusion: The offence was not made out on the facts alleged.

Final Conclusion: The application succeeded, the convictions were set aside, and the fine, if paid, was directed to be refunded.

Ratio Decidendi: Article 227 confers constitutional supervisory jurisdiction over judicial as well as administrative functioning of all courts and tribunals within the High Court's territory, and a finality clause in a statute cannot bar correction of jurisdictional illegality, patent error, or miscarriage of justice.

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