Professional disciplinary bodies are not Tribunals under Article 227 when they do not adjudicate a lis or exercise judicial power.

The Board of Discipline under the Chartered Accountants Act was treated as a professional disciplinary body, not a forum adjudicating a lis between contesting parties. Because it does not exercise transferred judicial power or determine rights and liabilities inter se, it is not a Tribunal for Article 227 purposes. Mere observance of natural justice or hearing both sides does not alter that character. On that basis, the Board is not amenable to supervisory jurisdiction under Article 227, and the challenge was not maintainable.

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Issues: Whether the Board of Discipline constituted under the Chartered Accountants Act, 1949 is a Tribunal amenable to supervisory jurisdiction under Article 227 of the Constitution of India.

Analysis: The Board was held to be a professional disciplinary body, not a forum deciding a lis between contesting parties. A Tribunal, for the purposes considered, must exercise transferred judicial power, decide disputes between parties, and adjudicate a lis. A complaint before the Board only triggers scrutiny of alleged professional misconduct and does not involve adjudication of rights and liabilities as between adversaries. The mere observance of natural justice or hearing both sides does not by itself convert such a body into a Tribunal. On that basis, the Board was found not to fall within the category of bodies subordinate to the High Court for Article 227 supervision.

Conclusion: The Board of Discipline is not a Tribunal within the meaning of Article 227 and the revision was not maintainable; the challenge failed.

Ratio Decidendi: A professional disciplinary body that does not decide a lis between contesting parties and is not vested with transferred judicial power is not a Tribunal amenable to Article 227 supervisory jurisdiction.

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