Certiorari barred in revenue recovery matters where officers acted under a bona fide belief in revenue-law authority.

The High Court's certiorari jurisdiction, inherited from the abolished Supreme Court and subject to historical and statutory limits, could not be used to interfere with matters concerning revenue or acts done in collection of revenue. The court rejected the argument that the bar applied only to ordinary original civil jurisdiction, and also rejected the contention that illegality alone removed the restraint. For jurisdictional purposes, the decisive question was whether the officer acted under a bona fide belief that he was proceeding under revenue law. On that basis, the court held that it had no jurisdiction to quash proceedings for recovery of income-tax arrears, and the application failed.

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Issues: Whether the High Court could issue a writ of certiorari to quash proceedings taken for recovery of income-tax arrears, in view of the statutory bar against interference in revenue matters.

Analysis: The jurisdiction to issue certiorari was traced to the powers preserved from the abolished Supreme Court and the High Court's inherited authority. Those powers were held to be subject to the historical and statutory limitation that no jurisdiction could be exercised in matters concerning revenue or acts done in the collection of revenue. The Court rejected the contention that the bar was confined to ordinary original civil jurisdiction or that it disappeared merely because the impugned act was said to be illegal. It also held that, for the purpose of the jurisdictional bar, the decisive consideration was whether the officer acted under a bona fide belief that he was proceeding according to the revenue law.

Conclusion: The High Court had no jurisdiction to issue certiorari in this revenue matter, and the application failed.

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