Recovery provisions cannot become adjudicatory forums unless the statute expressly grants power to decide disputed claims.

Section 17 of the Working Journalists Act is confined to recovery of money already found due by decree, award, or valid order, and does not authorise the State Government or specified authority to adjudicate the merits of a disputed employee claim. The provision is a summary recovery mechanism, not a forum with the procedural powers of a court or tribunal to decide contested issues of fact and law, so the authority had no jurisdiction to entertain the application at that stage. A challenge to the validity of section 17 could invoke Article 32, but the grievance against the interlocutory order did not itself enforce a fundamental right, so the petition was not maintainable on that ground.

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Issues: (i) Whether section 17 of the Working Journalists (Conditions of Service) and Miscellaneous Provisions Act, 1955 authorises the State Government or the specified authority to adjudicate the merits of a disputed claim by a newspaper employee, or is confined to recovery of money already found due. (ii) Whether the impugned order could be sustained in a petition under Article 32 of the Constitution of India.

Issue (i): Whether section 17 of the Working Journalists (Conditions of Service) and Miscellaneous Provisions Act, 1955 authorises the State Government or the specified authority to adjudicate the merits of a disputed claim by a newspaper employee, or is confined to recovery of money already found due.

Analysis: The statutory scheme treated section 17 as a recovery provision and not as a provision creating a forum for deciding disputed claims on the merits. The language of the section, its marginal note, and its place in the Act showed that the employee must first establish the amount due by decree, award, or valid order, after which the section operates as a summary mode of recovery. The Act did not confer on the State Government or the specified authority the powers normally associated with a court or tribunal for a formal adjudication of contested questions of fact and law. The absence of express procedural powers, especially when contrasted with the powers expressly conferred elsewhere in the Act and in analogous labour legislation, reinforced the restricted construction.

Conclusion: Section 17 does not authorise the specified authority to decide the merits of the employee's disputed claim and the authority had no jurisdiction to entertain the application at that stage.

Issue (ii): Whether the impugned order could be sustained in a petition under Article 32 of the Constitution of India.

Analysis: The challenge to the validity of section 17 could invoke Article 32, but once section 17 was upheld, the grievance against the authority's interlocutory order did not involve enforcement of a fundamental right. The petition therefore could not succeed as a substantive Article 32 remedy, even though the Court accepted the petitioner's construction of section 17 and disapproved the authority's assumption of jurisdiction.

Conclusion: The petition was not maintainable under Article 32 for the grievance ultimately pressed and failed on that technical ground.

Final Conclusion: Section 17 was construed as a limited recovery mechanism, the authority's assumption of adjudicatory jurisdiction was rejected, and the constitutional petition was dismissed for want of maintainability.

Ratio Decidendi: A statutory provision framed for recovery of money due cannot be expanded into a power to adjudicate disputed claims on their merits unless the statute expressly confers the necessary adjudicatory and procedural powers.

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