Quasi-judicial authorities lack inherent power to review final orders absent express or implied statutory authority.

A Collector acting under Section 47-A of the Indian Stamp Act, 1899 performs a quasi-judicial function, and review or recall is not an inherent power. Unless the statute expressly confers such authority or necessarily implies it, a concluded adjudication cannot be reopened by the same authority. On that basis, the Collector had no power to recall or review the earlier order, and the impugned recall order was liable to be set aside.

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Issues: Whether the Collector (Stamp) had any inherent or statutory power to recall or review an order passed under Section 47-A of the Indian Stamp Act, 1899.

Analysis: The Collector (Stamp) acts as a quasi-judicial authority while determining stamp duty liability under Section 47-A of the Indian Stamp Act, 1899. A review power is not an inherent power and must flow from an express provision in the statute or by necessary implication. The statute contains no such provision authorising the Collector to reopen, recall, or review a concluded determination made after adjudication. In the absence of statutory source, the subsequent exercise of recall/review jurisdiction is beyond authority and cannot be sustained.

Conclusion: The Collector (Stamp) had no power to recall or review the earlier order under Section 47-A of the Indian Stamp Act, 1899, and the impugned order was liable to be set aside.

Ratio Decidendi: A quasi-judicial authority cannot review or recall its own final order unless the power is expressly conferred by statute or necessarily implied therein.

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