Extension of time to complete adjudication is valid and does not amount to review when made in aid of justice.

The time fixed by a court for an adjudicating authority to pass a fresh order may be extended from time to time on sufficient cause, and such extension is treated as aid to compliance rather than a review of the earlier direction. The expiry of the original period does not by itself divest the authority of jurisdiction where the extension is necessary to avoid failure of justice and enable adjudication of a substantial revenue matter. Section 148 of the Code of Civil Procedure was held not to be essential for this purpose. The challenge that the authority had become functus officio on expiry of time was rejected.

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Issues: Whether the Court could extend the time fixed for the adjudicating authority to pass a fresh order and whether such extension amounted to a review of the earlier order.

Analysis: The time fixed by the Court for completion of adjudication was held to be capable of extension from time to time where sufficient cause existed. Such extension did not disturb the earlier order, but only enabled the authority to carry out the direction already issued. The power was treated as one exercised in aid of justice and not as a review jurisdiction. The Court also held that Section 148 of the Code of Civil Procedure was not necessary for this purpose, and that refusal to extend time in the facts would cause failure of justice by disabling the authority from adjudicating a substantial revenue matter.

Conclusion: The extension of time was valid and did not amount to review. The contention that the authority had lost jurisdiction on expiry of the original period was rejected.

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