Substance over label governs Letters Patent Appeal maintainability in writ proceedings involving Articles 226 and 227.

Maintainability of an intra-court appeal depends on the substance of the Single Judge's order and the principal relief granted, not the label of the writ petition. Where the challenge is directed at quashing an inferior tribunal's order, the proceeding may be treated as one under Article 226 even if Article 227 is also invoked. A petition seeking certiorari remains an original proceeding, and the presence of incidental supervisory elements does not by itself bar a Letters Patent Appeal. On that basis, the Letters Patent Appeal was held maintainable and the matter was directed to be heard on merits.

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Issues: (i) Whether a Letters Patent Appeal against the Single Judge's judgment was maintainable when the writ petition challenged an order of the Labour Court and the jurisdiction invoked had to be determined from the substance of the relief and not merely the label of the petition.

Analysis: The governing principle is that maintainability of an intra-court appeal depends on the real nature of the order passed by the Single Judge. Where the relief sought is to quash an inferior tribunal's decision, the proceeding may fall within Article 226 even if Article 227 is also mentioned. The determining factors are the pleadings, the nature of the challenge, and the principal relief granted, not the nomenclature of the writ petition or incidental supervisory elements. A petition invoking certiorari jurisdiction under Article 226 remains an original proceeding, and an appeal is not barred merely because the dispute also touches supervisory control under Article 227.

Conclusion: The Letters Patent Appeal was maintainable and the High Court erred in holding otherwise.

Final Conclusion: The order of the Division Bench was set aside and the writ appeal was directed to be heard on merits.

Ratio Decidendi: For deciding maintainability of an intra-court appeal, the court must examine the substance of the Single Judge's order and the principal relief granted; if the proceeding is in substance under Article 226, the mere presence of Article 227 or supervisory directions does not bar the appeal.

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