Administrative authorities cannot adjudicate marital status in proceedings for cancellation of identification certificates.

The Petitioners, claiming to be husband and wife, obtained a Certificate of Identification (COI) for Petitioner No. 2 from the Additional District Magistrate (ADM), Gangtok, based on her purported marriage to Petitioner No. 1

Respondent No. 5 subsequently challenged this, claiming she was the legally wedded wife of Petitioner No. 1. The ADM cancelled the COI, finding that Petitioner No. 2 obtained it by impersonating the legal wife

An appeal to the Appellate Authority (Land Revenue and Disaster Management Department) was dismissed, affirming the ADM's order

The Petitioners approached the High Court via a Writ Petition challenging these administrative cancellations

1. Whether the High Court, under Article 226, should interfere with the administrative findings of fact regarding the validity of a marriage

2. Whether an administrative authority has the jurisdiction to conclusively adjudicate the legal marital status of parties during an inquiry for a Certificate of Identification

The Court applied the principles governing the scope of judicial review under Article 226 of the Constitution of India, emphasizing that High Courts do not act as Appellate Courts to interfere with findings of fact unless specific parameters of irrationality or illegality are met

It further relied on the doctrine of limited administrative inquiry, which dictates that quasi-judicial administrative bodies must confine their scope to regulatory objectives (e.g., the issuance or cancellation of documents) rather than adjudicating complex issues of personal law or civil status

Such conclusive determinations are reserved for the exclusive jurisdiction of Civil or Family Courts

The Court reasoned that the inquiry conducted by the ADM and the Appellate Authority was "limited and objective," aimed solely at determining if the COI warranted cancellation under the regulatory framework

The Court held that administrative authorities cannot assume the character of a Civil Court to adjudicate the legality of a marriage

Upon examining the records, the Court found no "infirmity" or error in the ADM’s decision to cancel the COI based on the materials then available

However, the Court clarified that these administrative findings are not binding on the personal status of the parties; any determination of marital validity must be made by a competent Civil Court, which would then override the administrative decision

The Court held that the administrative orders remain subject to any future declaratory decree from a competent Civil or Family Court regarding the validity of the marriage

Liberty was reserved for the Petitioners to approach a Civil Court, subject to the law of limitation, to seek a formal declaration of their marital status