Statutory tribunal jurisdiction limited by the fee law; individual parents lacked standing and reconstitution directions were unauthorized.

The Bombay High Court noted that the Divisional Fee Regulatory Committee under the Maharashtra Educational Institutes (Regulation of Fees) Act is a statutory body of limited jurisdiction, and that individual parents had no implied locus standi to invoke it where the statute confined the reference process to specified contingencies. It also noted that the Committee's role was limited to fee disputes and incidental matters, so it could not direct reconstitution of the Parent-Teachers Association or its Executive Committee. On that basis, the fee committee orders were treated as beyond statutory power and unsustainable.

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Issues: (i) Whether individual parents had locus standi to invoke the Divisional Fee Regulatory Committee under the Maharashtra Educational Institutes (Regulation of Fees) Act; (ii) Whether the Committee could direct reconstitution of the Parent-Teachers Association and the Executive Committee while dealing with a fee dispute.

Issue (i): Whether individual parents had locus standi to invoke the Divisional Fee Regulatory Committee under the Maharashtra Educational Institutes (Regulation of Fees) Act.

Analysis: The statutory scheme vested the right to propose fees in the management and required the proposed fee to be placed before the Executive Committee of the Parent-Teachers Association. The Act provided a reference or appeal to the Divisional Fee Regulatory Committee only in the contingencies specifically contemplated by Section 6, and the authority was a creature of statute with powers confined to the matters expressly conferred. Reading Sections 6 and 10 harmoniously, the general adjudicatory power in fee disputes could not be expanded to permit initiation of proceedings by individual parents when the statute did not so provide.

Conclusion: The Committee had no jurisdiction to entertain the grievance at the instance of individual parents, and the impugned action on that basis was without authority of law.

Issue (ii): Whether the Committee could direct reconstitution of the Parent-Teachers Association and the Executive Committee while dealing with a fee dispute.

Analysis: The Committee's jurisdiction under the Act was limited to adjudicating fee disputes and matters incidental to that exercise. The constitution or reconstitution of the Parent-Teachers Association and its Executive Committee was not part of the fee-determination function conferred by the Act. Such directions travelled beyond the statutory remit and could not be sustained under Article 226 review where the authority had acted outside the scope of the enactment.

Conclusion: The direction to reconstitute the Parent-Teachers Association and the Executive Committee was without jurisdiction and unsustainable.

Final Conclusion: The fee committee orders were quashed and the writ petitions succeeded because the authority acted beyond the powers conferred by the statute.

Ratio Decidendi: A statutory tribunal of limited jurisdiction can act only within the authority expressly conferred by the statute, and a right of access to such forum cannot be implied in favour of persons whom the statute does not authorise to initiate proceedings.

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