High Court’s limited supervisory jurisdiction under Article 227 precludes interference with non-perverse Appellate Court findings.

The petitioners (representing a faction of PSRKS affiliated with BJMS) filed Title Suit No. 633/2024 seeking a declaration that the respondents (representing a faction affiliated with BRMS) have no right to use the Union's name or banner

The Trial Court granted a temporary injunction on 17.12.2024, restraining the respondents from using the Union's name

This was challenged by the respondents in Misc. Appeal No. 1/2025, where the First Appellate Court set aside the injunction on 28.05.2025, finding a lack of prima facie case

The petitioners moved the High Court under Article 227 of the Constitution, alleging the Appellate Court exceeded its jurisdiction by interfering without finding perversity or arbitrariness in the Trial Court's order

1. Whether the First Appellate Court was justified in setting aside the temporary injunction granted by the Trial Court

2. Whether the High Court, under its supervisory jurisdiction under Article 227, should interfere with the order of the First Appellate Court

Article 227 of the Constitution of India, which governs the High Court's power of superintendence over subordinate courts

The principle established in Shalini Shyam Shetty v. Rajendra Shankar Patil, holding that Article 227 is to be exercised sparingly and not as a "court of appeal" to correct mere errors of fact or law unless there is patent perversity

Order 39 Rules 1 & 2 of the CPC (the "three golden principles": prima facie case, balance of convenience, and irreparable loss)

The principle in Wander Ltd. v. Antox India Pvt. Ltd. regarding the limited scope of appellate interference in discretionary orders

The High Court examined whether the Appellate Court's decision to vacate the injunction was "perverse" or merely "erroneous"

The court noted that while it might have taken a different view on the existence of a prima facie case, the Appellate Court provided reasons for its reversal, which prevents the decision from being classified as legally perverse

The High Court emphasized that under Article 227, it cannot substitute its own opinion for that of the lower court simply because another view is possible

It observed that the core dispute—which faction is the "original" Union—is a matter for trial in the pending Title Suit, and the Appellate Court's decision to allow both factions to operate (subject to conditions) did not warrant supervisory intervention

The Revision Petition was disposed of with a directive for the ends of justice: the respondents are permitted to use the name "Purvottar Simanta Railway Karmachari Sangh" during the suit's pendency, provided they specifically mention their affiliation to the "Bharatiya Railway Mazdoor Sangh (BRMS)" to distinguish them from the petitioners' BJMS-affiliated faction