Article 227 Supervisory Jurisdiction Not Extensible to Re-appreciation of Disputed Factual Findings or Evidentiary Value

The Petitioner (wife) challenged an order dated 24.04.2026 passed by the Family Court-01, Dwarka, in a matrimonial dispute (HMA No. 2954/2025).

The Petitioner contended that the Family Court erroneously relied on a Summon Report dated 24.11.2025, which she claimed pertained to the wrong address (C-136 instead of C-136-A) and contained incorrect statements from a purported landlord.

The Petitioner produced a private document alleged to be a statement from the landlady’s husband to prove she did not reside at the address mentioned in the report.

She sought to set aside the order by invoking the High Court’s supervisory jurisdiction.

1. Whether the findings of the Family Court based on the Summon Report involved a jurisdictional error or manifest illegality warranting interference under Article 227 of the Constitution.

2. Whether the High Court, in its supervisory capacity, can re-appreciate disputed questions of fact or the evidentiary value of documents relied upon by a subordinate court.

The Court applied the settled principles governing Article 227 of the Constitution of India, 1950, which establishes the High Court's power of superintendence over subordinate courts.

The court emphasized that this jurisdiction is strictly supervisory, not appellate, and is intended only to ensure subordinate courts act within their bounds of authority.

Supervisory jurisdiction does not permit a fresh appreciation of disputed facts or the substitution of the lower court's view with that of the High Court merely because an alternative view is possible.

The Court observed that the Petitioner’s challenge was fundamentally rooted in the appreciation of factual material—specifically the accuracy of the Summon Report and the identity of the premises.

The Court reasoned that determining the validity of these claims would require a detailed examination of the evidentiary value of the report and the authenticity of the Petitioner’s private documents.

Since these matters fall squarely within the domain of the Trial Court's fact-finding powers, the High Court held that re-evaluating such evidence would exceed the limited contours of Article 227.

The Court found no "patent perversity" or "manifest illegality" in the Family Court's approach to justify judicial intervention.

The High Court dismissed the petition and all pending applications, affirming that the supervisory jurisdiction under Article 227 cannot be used as a substitute for an appeal to re-agitate factual disputes.