Article 227 jurisdiction cannot correct mere errors absent perversity or manifest injustice.

Kuldeep Raj filed a suit for permanent prohibitory injunction concerning 1 marla and 4 sarsai of land, claiming ownership under a registered sale deed dated 13 March 2014 and possession supported by mutation and girdawari records.

The Munsiff, Akhnoor, initially granted an ex parte restraint and, on 5 August 2024, made it absolute, restraining the defendants from interfering with the land described in the sale deed, subject to Kuldeep Raj undertaking to demolish any construction found to extend beyond the purchased land.

Bachan Lal’s appeal was dismissed by the Principal District Judge, Jammu, on 18 December 2024.

Bachan Lal also relied on a separate suit brought by his sisters challenging the sale deed, in which another court had directed the parties to maintain status quo concerning the property.

He invoked Article 227 of the Constitution to challenge both orders.

Whether the petition under Article 227 disclosed grounds warranting the High Court’s supervisory intervention in the concurrent orders of the courts below

Whether the separate status quo order and the injunction order concerning the same property established an error warranting interference under Article 227

Article 227 supervisory jurisdiction is exceptional and is not an appellate jurisdiction for correcting mere errors of law or fact; it is exercised to keep subordinate courts within the bounds of their authority and may be invoked for patent perversity, gross or manifest failure of justice, or violation of natural justice

Relying principally on Shalini Shyam Shetty v. Rajendra Shankar Patil, 2010 AIR SCW 6387, and also referring to Babubhai Jamnadas Patel v. State of Gujarat and Radhey Shyam v. Chhabi Nath, the Court reiterated that Article 227 must be exercised sparingly and in accordance with strict judicial discipline.

The High Court considered whether the impugned orders fell within the limited grounds for Article 227 intervention. It found that the courts below had exercised their jurisdiction and had neither exceeded nor refused to exercise their authority; the orders were not shown to be perverse or to cause a manifest failure of justice or breach of natural justice.

The injunction was confined to the land described in the sale deed and was subject to an undertaking requiring demolition if construction were found to extend beyond the land purchased, which the Court considered sufficient to protect Bachan Lal’s interests.

The asserted existence of the separate status quo order did not, in the Court’s assessment, establish a basis for supervisory interference.

It directed the Trial Court to decide the suit without being influenced by the High Court’s observations.