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Issues: Whether the civil court's jurisdiction was impliedly barred in a dispute arising under the central excise law, and whether the suit and injunction petition could be entertained despite the statutory appeal and revisional machinery.
Analysis: The dispute arose from excise proceedings in which the statute provided a full adjudicatory hierarchy, including assessment, appeal and further recourse to the High Court, with the possibility of appeal to the Supreme Court. In such a scheme, the Court held that the remedy under the civil suit was excluded by necessary implication. The presence of a detailed statutory mechanism for redressal meant that the civil court could not be invoked to challenge the excise orders.
Conclusion: The civil court's jurisdiction was impliedly barred, and the suit could not be entertained; the objection to jurisdiction was rejected.
Final Conclusion: The appeal failed because the impugned civil court order refusing injunction was upheld on the ground that the excise statute supplied an exclusive remedy and excluded civil court intervention.
Ratio Decidendi: Where a taxing statute creates rights and liabilities and provides a complete machinery for adjudication and appellate redress, the jurisdiction of the civil court is excluded by necessary implication.