No inherent review power for statutory tribunals absent express legal authority; restoration of merits disposal was rejected.

A statutory tribunal has no inherent power to review or restore an appeal disposed of on merits unless such jurisdiction is expressly conferred by law or arises by necessary implication. Applying that principle, the Tribunal found that its rules did not create any review power and therefore it could not reopen an order passed on merits merely because the appellant had not appeared. The restoration petition was rejected for want of statutory authority.

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Issues: Whether the Tribunal had inherent power to review or restore an appeal disposed of on merits in the absence of any express statutory provision conferring such power.

Analysis: The application sought restoration of an appeal earlier disposed of on merits for non-appearance of the appellant. The governing principle applied was that the power of review is not an inherent power and can exist only when conferred by law either expressly or by necessary implication. For a statutory tribunal, such power cannot be assumed in the absence of a specific enabling provision, and the Tribunal rules did not confer any such review jurisdiction.

Conclusion: The Tribunal held that it had no power to review its order on merits, and the restoration petition was rejected.

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