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Issues: Whether Section 13(2) of the Chhattisgarh Rent Control Act, 2011, which provided for a direct statutory appeal to the Supreme Court from the Rent Control Tribunal, was within the legislative competence of the State Legislature and valid in light of the Constitution.
Analysis: The State Legislature had competence under Entry 18 of List II and Article 323B to enact a rent control law and provide for tribunals dealing with tenancy and rent disputes. However, Entry 77 of List I reserves to Parliament the power to legislate on the constitution, organisation, jurisdiction and powers of the Supreme Court, while Entries 65 of List II and 46 of List III expressly exclude the Supreme Court from the State Legislature's power over court jurisdiction. The Court held that a statutory second appeal to the Supreme Court is not ancillary to the State's power over rent control, does not flow from Article 136, and cannot be validated by Presidential assent under Article 200. The Court further held that Article 138(2) requires a special agreement between the Union and a State together with parliamentary law, which was absent.
Conclusion: Section 13(2) was held to be ultra vires the Constitution and beyond the legislative competence of the State Legislature.
Final Conclusion: The appeal failed, and the impugned statutory provision conferring direct appellate jurisdiction on the Supreme Court was declared void and inoperative.
Ratio Decidendi: A State Legislature cannot, by a rent control enactment or by Presidential assent, confer a statutory appeal to the Supreme Court, because the Supreme Court's jurisdiction and powers fall within the exclusive legislative domain of Parliament unless Constitutionally authorised by a valid parliamentary framework and special agreement under Article 138(2).