Supreme Court on Article 227: High Courts Cannot Re-Appreciate Evidence or Act as Appellate Courts -

The Supreme Court reiterates limits of Article 227 jurisdiction, holding that High Courts cannot re-evaluate evidence or act as appellate courts. Read key principles for law aspirants.

In a significant ruling for judicial jurisprudence, the Supreme Court of India has once again clarified the limited scope of supervisory jurisdiction exercised by High Courts under Article 227 of the Constitution of India.

The Court emphasized that High Courts cannot function as appellate courts while exercising their powers under Article 227 and must refrain from re-evaluating evidence or substituting their own findings over those of subordinate courts.

Understanding Article 227: Supervisory, Not Appellate Jurisdiction

Article 227 empowers High Courts to supervise the functioning of subordinate courts and tribunals. However, this power is limited and corrective in nature, not expansive or appellate.

The bench comprising Justice Aravind Kumar and Justice N. V. Anjaria laid down clear principles governing the exercise of this jurisdiction.

Key Principles Laid Down by the Supreme Court

The Court outlined when High Courts can intervene under Article 227:

Grounds for Exercising Supervisory Jurisdiction

High Courts may interfere only in exceptional situations such as:

When a court or tribunal assumes jurisdiction it does not possess
When there is a gross abuse of jurisdiction
When there is an unjustifiable refusal to exercise jurisdiction

No Role as an Appellate Court

The Supreme Court made it clear that:

High Courts cannot act as appellate courts under Article 227
They cannot substitute their own judgment for that of subordinate courts
Mere disagreement with a decision is not a valid ground for interference

No Re-Appreciation of Evidence

The Court emphasized that:

High Courts cannot re-evaluate or reweigh evidence
Supervisory jurisdiction is not meant to correct every factual or legal error
Intervention is justified only when findings are perverse or irrational

Case Background: NICE Land Compensation Dispute

The case arose from a dispute involving Nandi Infrastructure Corridor Enterprises Ltd. and landowners in Bengaluru.

In 2007, a compromise agreement allowed NICE to acquire land for a road project
NICE agreed to either provide alternate land or compensate landowners
Upon failure to provide alternate land, the matter went to the executing court

Executing Court’s Decision

Compensation fixed at ₹1,000 per sq. ft.

High Court’s Intervention

Reduced compensation to ₹500 per sq. ft. under Article 227

Supreme Court’s Verdict

The Supreme Court set aside the High Court’s decision and restored the executing court’s order.

The Court held that:

The High Court exceeded its jurisdiction by re-determining compensation
It effectively acted as an appellate court, which is impermissible under Article 227
There was no jurisdictional error in the executing court’s decision

The judgment reaffirmed that supervisory jurisdiction is narrow and restricted, and cannot be used to replace a reasonable decision with another view.

Why This Judgment Matters for Law Aspirants

This ruling is crucial for students preparing for:

Judicial Services Examinations
CLAT PG / LLM Entrance
UGC NET Law

Key Takeaways:

Article 227 is not equivalent to appellate jurisdiction
High Courts can intervene only in jurisdictional errors or perversity
Re-appreciation of evidence is strictly prohibited

Case Title

Nandi Infrastructure Corridor Enterprises Ltd. & Anr. v. B. Gurappa Naidu & Ors.

Conclusion

This judgment reinforces the principle that judicial discipline requires courts to operate within defined boundaries. By limiting the scope of Article 227, the Supreme Court has ensured that the hierarchy of courts is respected and that High Courts do not overstep into appellate functions.