High Court jurisdiction under Article 226 follows bench allocation rules; PIL labeling cannot shift a petition to a Division Bench.

A writ petition under Article 226 challenging an order of the National Environment Appellate Authority could not be entertained by a Division Bench merely because it was styled as a public interest litigation. The applicable Delhi High Court Rules allocated such petitions, including PIL matters, to a Single Judge unless a stated exception applied. Labeling the petition as PIL did not confer Division Bench jurisdiction. The matter therefore ought to have been heard by a Single Judge, and placing it before a Division Bench contrary to the rules was improper.

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Issues: Whether a writ petition styled as a public interest litigation for quashing an order of the National Environment Appellate Authority could be entertained by a Division Bench of the Delhi High Court instead of a Single Judge.

Analysis: The relevant Delhi High Court Rules provided that petitions under Article 226 of the Constitution, including those pertaining to public interest litigation, ordinarily fell within the jurisdiction of a Single Judge, subject to the stated exceptions. A petition challenging the order of the National Environment Appellate Authority did not fall within the category that could be treated as a Division Bench matter merely because it was presented as a public interest litigation. The practice of placing the matter before a Division Bench by adopting that label was contrary to the allocation of jurisdiction under the High Court Rules. The Division Bench, therefore, ought not to have entertained and decided the petition on merits.

Conclusion: The petition was not maintainable before the Division Bench and had to be heard by a Single Judge.

Ratio Decidendi: A petition challenging an order under Article 226 must be heard by the Bench assigned by the applicable High Court Rules, and its characterization as public interest litigation does not confer jurisdiction on a Division Bench where the rules allocate such matters to a Single Judge.

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