Revisional jurisdiction limits: High Court cannot correct non-jurisdictional errors or pass prejudicial ex parte clarification orders without notice.

Revisional jurisdiction under Section 115 CPC is confined to jurisdictional error, failure to exercise jurisdiction, or material irregularity; it cannot be used to correct mere errors of fact or law. The Supreme Court held that the High Court exceeded those limits by interfering with the Additional District Judge's stay of proceedings under Section 30 of the Land Acquisition Act, because the subordinate court had acted within jurisdiction. It also held that a prejudicial ex parte order on a clarification application under Sections 151/141 CPC could not be passed without notice to the affected party. The impugned High Court orders were quashed, leaving further proceedings open in accordance with law.

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Issues: (i) Whether the High Court could interfere in revision with the Additional District Judge's order staying the proceedings under Section 30 of the Land Acquisition Act; (ii) whether the ex parte order made on the clarification application under Sections 151/141 of the Code of Civil Procedure was sustainable.

Issue (i): Whether the High Court could interfere in revision with the Additional District Judge's order staying the proceedings under Section 30 of the Land Acquisition Act.

Analysis: The revisional power under Section 115 of the Code of Civil Procedure is confined to cases where the subordinate court has exercised jurisdiction not vested in it, failed to exercise jurisdiction vested in it, or acted illegally or with material irregularity. Errors of fact, or even errors of law unconnected with jurisdiction, do not justify revision. The Additional District Judge had not acted without jurisdiction or with material irregularity in directing the proceedings to remain stayed pending the appeal. The High Court, therefore, exceeded the limits of revisional jurisdiction and treated the matter as if it were an appeal.

Conclusion: The High Court's order interfering with the stay order was unsustainable and was liable to be set aside.

Issue (ii): Whether the ex parte order made on the clarification application under Sections 151/141 of the Code of Civil Procedure was sustainable.

Analysis: The application for clarification referred to the later judicial order of the Additional District Judge, which had been made after hearing both sides. The High Court, without notice to the appellant, passed an ex parte order that effectively reversed that judicial order. Such a course could not properly be adopted on a miscellaneous clarification application, and the affected party was entitled to notice before any order prejudicial to it was made.

Conclusion: The ex parte clarification order was unsustainable and was liable to be set aside.

Final Conclusion: The impugned High Court orders were quashed, and the matter was left open for appropriate proceedings in accordance with law.

Ratio Decidendi: Revisional jurisdiction under Section 115 of the Code of Civil Procedure cannot be used to correct non-jurisdictional errors of fact or law, and a prejudicial order affecting a party's rights cannot be made ex parte on a clarification application without notice.

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