High Courts Cannot Reassess Materials Considered by Trial Courts

Source: Supreme Court 

Why in News? 

A bench of Justice J.K. Maheshwari and Justice Atul S. Chandurkar of the Supreme Court, in Vinay Raghunath Deshmukh v. Natwarlal Shamji Gada & Anr. (2026), held that a High Court exercising its supervisory jurisdiction under Article 227 of the Constitution cannot interfere with the findings of subordinate courts by reassessing or re-examining the materials on merits. 

• The Court set aside the Bombay High Court's judgment, which had interfered with an Appellate Court's order allowing the appellant to amend an eviction suit, holding that the High Court had impermissibly acted as an appellate court rather than confining itself to a supervisory examination of jurisdictional error. 

What was the Background of Vinay Raghunath Deshmukh v. Natwarlal Shamji Gada & Anr. (2026) Case? 

• The appellant was the son of a landlord who had originally instituted a suit for eviction on the ground of bonafide need for himself and his family members. 
• Following the death of his father, the appellant sought to amend the plaint to include an additional ground of eviction based on bonafide need arising from a subsequent event. 
• The Trial Court refused leave to amend the plaint. 
• The Appellate Court, however, allowed the amendment to the suit. 
• Aggrieved, the tenant moved the Bombay High Court under Article 227 of the Constitution. 
• The High Court interfered with the Appellate Court's decision by entering into the merits of the case, prompting the appellant to file an appeal before the Supreme Court. 

What were the Court's Observations? 

The Court made the following key observations: 

Scope of Article 227 — Supervisory, Not Appellate: 

• The Court emphatically reiterated that the supervisory jurisdiction under Article 227 is confined to examining whether an inferior court or tribunal has proceeded within the parameters of its jurisdiction. 
• It is not open to the High Court, while exercising this jurisdiction, to act as an appellate court and review or reassess the evidence or materials upon which the subordinate court has passed its order. 

High Court's Error in the Present Case: 

• Instead of restricting its examination to the question of whether the Appellate Court had exceeded its jurisdiction, the High Court entered into the merits of the case and re-examined the Appellate Court's decision. 
• This amounted to an impermissible exercise of appellate jurisdiction under the guise of supervisory power, which the Supreme Court found to be legally unsustainable. 

Power to Allow Amendment Not in Dispute: 

• The Court noted that the Appellate Court's power to allow amendment of a plaint under Order VI Rule XVII of the Code of Civil Procedure was not disputed. 
• Since the Appellate Court had exercised a discretion expressly vested in it by statute, and there was neither a jurisdictional error nor a statutory bar to allowing the amendment on the basis of subsequent events, there was no occasion for the High Court to interfere. 

Reliance on Precedent: 

• The Court placed reliance on Raj Kumar Bhatia v. Subhash Chander Bhatia (2017), which had authoritatively held that Article 227 is confined to examining whether an inferior court or tribunal has proceeded within its jurisdictional limits, and that the High Court does not, in exercise of that jurisdiction, act as an appellate court or reassess the evidence. 

Outcome: 

• The Supreme Court allowed the appeal and set aside the Bombay High Court's judgment, restoring the Appellate Court's order permitting the amendment of the plaint. 

What is Article 227 of the Constitution of India? 

Article 227 – Power of Superintendence of High Courts 

• Every High Court has superintendence over all courts and tribunals within its territorial jurisdiction. 
• This power includes the authority to:  
• Call for returns from subordinate courts. 
• Make rules and prescribe forms for regulating practice and proceedings. 
• Prescribe formats for books, entries, and accounts maintained by court officers. 
• High Courts can also settle fee tables for sheriffs, clerks, court officers, attorneys, advocates, and pleaders — subject to:  
• Rules/forms/tables not being inconsistent with existing law 
• Prior approval of the Governor. 
• Exception: This superintendence power does not extend to courts or tribunals constituted under laws relating to the Armed Forces.