Implied exclusion of civil court jurisdiction applies to statutory inam-estate determinations, while jurisdictional facts remain reviewable.

A shrotriem village was treated as an "estate" under the Madras Estates (Reduction of Rent) Act, 1947 because the grant covered the named village, including dry lands and poramboke, and minor inams did not amount to a reservation excluding it from the statutory definition; the rent-reduction notification was therefore valid. Under the Madras Estates (Abolition and Conversion into Ryotwari) Act, 1948, the scheme conferring power on the Settlement Officer, with notice, hearing, evidence, appeal and finality, impliedly excluded civil court jurisdiction on the statutory question whether an admitted inam village was an inam estate. Civil court scrutiny remained possible only on the preliminary jurisdictional fact that the property was an inam village.

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Issues: (i) whether the shrotriem village fell within the definition of an "estate" under the Madras Estates (Reduction of Rent) Act, 1947 so as to sustain the rent-reduction notification; (ii) whether the civil court's jurisdiction was barred in a suit challenging the determination that the village was an "inam estate" under the Madras Estates (Abolition and Conversion into Ryotwari) Act, 1948.

Issue (i): whether the shrotriem village fell within the definition of an "estate" under the Madras Estates (Reduction of Rent) Act, 1947 so as to sustain the rent-reduction notification.

Analysis: The relevant definition in the Estates Land Act treated as an estate any inam village whose grant had been made, confirmed or recognised by Government, and Explanation (1) covered a named village grant notwithstanding exclusion of lands already granted on service or reserved for communal purpose. The entries in the Inam Fair Register and the Deputy Collector's remarks showed that the grant was of the named village, that the dry lands and poramboke formed part of the grant, and that the so-called minor inams did not amount to a reservation by the grantor so as to exclude the village from the statutory definition.

Conclusion: The village was an estate within the meaning of the Rent Reduction Act, and the notification issued under that Act was valid.

Issue (ii): whether the civil court's jurisdiction was barred in a suit challenging the determination that the village was an "inam estate" under the Madras Estates (Abolition and Conversion into Ryotwari) Act, 1948.

Analysis: Section 9 of the Abolition Act vested in the Settlement Officer, subject to appeal, the power to determine whether any inam village was an inam estate, provided a procedure with notice, hearing, evidence and appeal to a three-member Tribunal. The scheme, coupled with the finality and binding effect provisions, showed an implied exclusion of civil court jurisdiction in relation to the statutory question whether an admitted inam village was an inam estate. At the same time, the existence of the preliminary fact that the property was an inam village was a jurisdictional fact; if that fact were absent, the statutory authorities could not assume jurisdiction, and that point could still be examined in an ordinary civil proceeding. On the facts, however, the village was already found to be an inam village, so the bar operated.

Conclusion: Civil court jurisdiction was barred on the merits of the statutory question, and the determination that the village was an inam estate stood; the defective dismissal of the appeal by two members did not assist the appellants.

Final Conclusion: The statutory authorities had validly treated the village as an estate for rent-reduction purposes, and the civil suit could not reopen the merits of the inam-estate determination under the Abolition Act. The appeal therefore failed.

Ratio Decidendi: Where a special statute creates a complete machinery for deciding whether a property answers a statutory description and gives finality to that decision, civil court jurisdiction is impliedly excluded as to that statutory issue, though not as to the existence of the preliminary jurisdictional fact on which the tribunal's competence depends.

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