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Issues: Whether the High Court was justified in sustaining the respondent's challenge to the surplus land proceedings by permitting recourse to Section 151 of the Code of Civil Procedure, 1908 despite the availability of a statutory remedy under the U.P. Imposition of Ceiling on Land Holdings Act, 1954.
Analysis: Section 151 of the Code of Civil Procedure, 1908 is only supplementary and cannot be invoked to override or bypass an express statutory scheme. Where the special Act provides a specific remedy, the inherent power of the court cannot be used to reopen concluded proceedings, particularly when the statutory appeal under Section 12 of the U.P. Imposition of Ceiling on Land Holdings Act, 1954 was not availed. The High Court's order contained no real reasoning and overlooked the settled principle that inherent jurisdiction is unavailable when an express remedy exists.
Conclusion: The invocation of Section 151 of the Code of Civil Procedure, 1908 was impermissible, and the High Court's orders could not be sustained.