No intra-court appeal lies against a Single Bench order arising from judicial proceedings of a Civil Court.

The appellant challenged an order passed by a Single Bench of the Madhya Pradesh High Court in a miscellaneous petition.

The Single Bench had overturned a trial court decision that refused to admit additional documents—specifically related to prior civil and criminal litigation—under Order 8 Rule 1(3) of the CPC.

The High Court Registry raised an objection regarding the maintainability of this intra-court writ appeal.

The appellant argued that the writ appeal should be entertained given the nature of the Single Bench’s jurisdiction under Article 227 of the Constitution.

1. Whether a writ appeal is maintainable before a Division Bench against an order passed by a Single Judge in proceedings arising from a subordinate court's order in a civil suit.

2. Whether the specific statutory framework in Madhya Pradesh permits such an appeal.

The Court applied the Madhya Pradesh Uchcha Nyayalaya (Khand Nyayapeeth Ko Appeal) Adhiniyam, 2005, which governs the maintainability of intra-court appeals.

It further relied on the Full Bench decision in Shailendra Kumar v. State of M.P. and the Supreme Court precedent in Ram Kishan Fauji v. State of Haryana, which establish that no writ appeal lies against an order passed by a Single Judge in proceedings arising out of an order of a judicial court in civil or criminal matters.

The Court distinguished Kapil Agrawal v. Sanjay Sharma by noting that the legal framework for Letter Patent Appeals in other states differs from the specific 2005 Adhiniyam in Madhya Pradesh.

The Court reasoned that the right to appeal is a statutory creation and, in Madhya Pradesh, it is strictly confined by the 2005 Adhiniyam.

The Bench observed that the impugned order by the Single Judge arose from a miscellaneous petition (under Article 227) challenging a trial court's interlocutory order regarding the production of documents.

Following established judicial discipline, the Court held that when a Single Judge exercises supervisory jurisdiction over a judicial court, an intra-court appeal is barred.

The Court rejected the appellant's reliance on cases from other jurisdictions, stating that the specific enactment in Madhya Pradesh limits the Division Bench's jurisdiction in such matters.

The Court upheld the Registry's objection and dismissed the writ appeal as not maintainable.