Chamber jurisdiction for condonation delay in statutory appeals upheld; differential treatment of special leave petitions passes Article 14 scrutiny.

Under the Supreme Court Rules, applications for condonation of delay in statutory appeals fell within chamber business and could validly be dismissed by a single judge sitting in chambers. The Court relied on prior construction of the same rule and settled practice to uphold that procedural arrangement. It also held that treating condonation applications in statutory appeals differently from those in special leave petitions did not violate Article 14, because Article 136 matters form a distinct class by reason of the Court's special and residuary jurisdiction. The chamber practice was upheld, reference to a larger Bench was declined, and the review petitions were dismissed.

---

---

Issues: (i) Whether a single judge sitting in chambers was competent to dismiss applications for condonation of delay in statutory appeals. (ii) Whether the different treatment of applications for condonation of delay in statutory appeals and in special leave petitions offended Article 14 of the Constitution of India.

Issue (i): Whether a single judge sitting in chambers was competent to dismiss applications for condonation of delay in statutory appeals.

Analysis: The rules governing chamber business empowered a single judge to deal with applications for enlargement or abridgement of time, except where the time was fixed by the court and except applications for condonation of delay in filing special leave petitions. The earlier decision construing the same rule had held that applications for condonation of delay in filing statutory appeals fell within chamber business. That construction had been followed as settled practice since 1966. The Court found no compelling reason to depart from that interpretation and held that the arrangement of court business under the Rules validly permitted such matters to be dealt with in chambers.

Conclusion: A single judge sitting in chambers was competent to dismiss applications for condonation of delay in statutory appeals.

Issue (ii): Whether the different treatment of applications for condonation of delay in statutory appeals and in special leave petitions offended Article 14 of the Constitution of India.

Analysis: The Court held that applications under Article 136 constitute a distinct class because they invoke the Court's special and residuary jurisdiction, and could legitimately be treated differently from statutory appeals. The exception carved out for special leave petitions was therefore not arbitrary. The Court found no constitutional infirmity in the classification or in the settled practice of disposal of such applications in chambers.

Conclusion: The differential treatment did not violate Article 14 of the Constitution of India.

Final Conclusion: The settled chamber practice was upheld, the reference to a larger Bench was declined, and the review petitions were dismissed.

Ratio Decidendi: Under the Supreme Court Rules, applications for condonation of delay in statutory appeals fall within chamber business, and a distinct procedural treatment for special leave petitions under Article 136 does not offend equality where the classification is based on the special nature of that jurisdiction.

---