Statutory review and condonation powers cannot be implied where the Act is silent; time-barred appeal was quashed.

A statutory authority has no inherent power of review, and where the governing enactment does not confer such power, an order rejecting a review application is not separately appealable. The Regional Transport Authority therefore could not review its own order, and no appeal lay from the rejection of review. Where a special statute prescribes a 30-day appeal period and contains no provision for condonation of delay, the appellate body cannot extend time on equitable grounds or treat a late appeal as within time. The Appellate Board accordingly lacked jurisdiction to entertain the time-barred appeal, and the impugned appellate order was quashed.

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Issues: (i) Whether the Regional Transport Authority had any power to review its own order and whether an appeal lay against the order rejecting such review. (ii) Whether the Appellate Board had jurisdiction to treat the later appeal as an appeal against the original order, condone the delay, and entertain it as within time.

Issue (i): Whether the Regional Transport Authority had any power to review its own order and whether an appeal lay against the order rejecting such review.

Analysis: The statutory scheme contained no provision conferring a power of review on the Regional Transport Authority or the Appellate Board. A power of review is not inherent in a statutory authority. Once the authority has exercised its decision-making power, it becomes functus officio except for correction of grave clerical mistakes. Since the Act provided an appeal only in respect of the matters specifically enumerated, and did not provide for an appeal from an order rejecting a review application, such an appeal could not be maintained.

Conclusion: The Regional Transport Authority had no power to review its order, and no appeal lay against the order rejecting the review application.

Issue (ii): Whether the Appellate Board had jurisdiction to treat the later appeal as an appeal against the original order, condone the delay, and entertain it as within time.

Analysis: The appeal against the original order was filed after expiry of the thirty-day period prescribed by the rules made under the Act. The special law did not incorporate any provision analogous to Section 5 of the Indian Limitation Act, 1908, authorising condonation of delay. Where a special statute prescribes a limitation period and no enabling provision exists, the appellate authority cannot extend time on equitable grounds. Section 21 of the General Clauses Act, 1897 was also inapplicable because the statutory right of appeal was not expressed in terms that permitted alteration or rescission of the original decision in the manner suggested.

Conclusion: The Appellate Board had no jurisdiction to condone the delay or entertain the time-barred appeal, and its order was without jurisdiction.

Final Conclusion: The writ petition succeeded, the impugned appellate order was quashed, and the petitioner obtained relief with costs.

Ratio Decidendi: A statutory authority has no inherent power of review or condonation of delay unless the governing enactment expressly confers it, and an appeal filed beyond the prescribed period under a special statute cannot be validly entertained without such authority.

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