Backward Classes Commission cannot adjudicate private commercial disputes or direct recovery of quantified compensation.

The appellant agreed to purchase a Preet Harvester Machine, Model No. 4949, from respondent No. 3 for ₹21,00,000. He paid ₹30,000 as advance on 31 July 2020 and the balance ₹20,70,000 through three demand drafts dated 9 September 2020. Although delivery was initially promised on successive dates, the machine was not supplied.

On 22 October 2020, documents relating to a different model were allegedly provided, and the appellant was informed that the booked model could not be supplied for the agreed price.

After approaching the police and allegedly being assaulted in connection with a proposed compromise, the appellant approached the Chhattisgarh State Backward Classes Commission.

Upon examining the statements and documents, the Commission recommended recovery of compensation from respondent No. 3 through the Collector, Durg, and payment of the amount to the appellant.

Respondent No. 3 challenged the Commission’s proceedings in WPC No. 598 of 2023. The learned Single Judge allowed the writ petition and quashed the proceedings on 17 June 2026. The appellant preferred the present intra-Court appeal against that order.

Whether the Chhattisgarh State Backward Classes Commission, exercising powers under the Chhattisgarh State Backward Classes Commission Adhiniyam, 1995, could adjudicate a private commercial dispute and direct recovery of a quantified amount from one private party for payment to another?

Whether the learned Single Judge was justified in quashing the Commission’s proceedings in their entirety, rather than modifying or remitting the matter for reconsideration?

The Court applied Section 9 of the Chhattisgarh State Backward Classes Commission Adhiniyam, 1995, under which the Commission’s functions are primarily advisory and recommendatory, including safeguarding the interests of backward classes, monitoring welfare programmes, tendering advice to the State Government, and performing assigned functions.

The statutory scheme does not confer jurisdiction on the Commission to adjudicate private commercial disputes or issue an executable order directing payment of a quantified sum by one private party to another.

The Court relied on All India Indian Overseas Bank Scheduled Castes and Scheduled Tribes Employees Welfare Association v. Union of India, (1996) 6 SCC 606, which establishes that the conferment of certain powers of a Civil Court for inquiry or investigation does not transform a Commission into a Civil Court or confer adjudicatory jurisdiction over rights and liabilities.

The substantive nature and effect of an order, rather than its description as a “recommendation,” determines whether it is adjudicatory and executable.

The dispute concerned non-delivery or alleged substitution of a harvester pursuant to a private commercial transaction between the appellant and respondent No. 3.

Although the Commission could inquire into grievances and make recommendations within its statutory mandate, it went further by determining a monetary liability, specifying the amount to be recovered, directing the Collector to recover it from respondent No. 3, and requiring payment to the appellant.

In substance, this amounted to adjudication and enforcement of a private monetary claim, powers not conferred by Section 9 of the 1995 Adhiniyam.

The fact that the Commission’s decision was styled as a recommendation did not alter its operative character.

Since the proceedings were fundamentally beyond the Commission’s jurisdiction, the learned Single Judge was entitled to quash them in their entirety; modification or remittal was not warranted.

The learned Single Judge’s order dated 17 June 2026 quashing the Commission’s proceedings was affirmed.

The writ appeal was dismissed as devoid of merit, with no order as to costs.