Supreme Court Lays Down Principles Limiting High Court Intervention Under Article 227

In Nandi Infrastructure Corridor Enterprises Ltd. & Anr. v. B. Gurappa Naidu & Ors., the Supreme Court has clarified the scope of Article 227 of the Constitution, emphasising the limited nature of the High Court’s supervisory jurisdiction.

The Court reaffirmed that High Courts cannot act as appellate bodies while exercising powers under Article 227. Their role is not to re-evaluate evidence or replace findings of subordinate courts merely because another view is possible.

The bench comprising Justice Aravind Kumar and Justice N.V. Anjaria laid down clear principles governing the exercise of this jurisdiction. It stated that supervisory powers must be used sparingly and only in specific situations involving jurisdictional errors.

The Court observed that Article 227 can be invoked only when there is an “unwarranted assumption of jurisdiction,” a “gross abuse of jurisdiction,” or an “unjustifiable refusal to exercise jurisdiction” by a subordinate court or tribunal.

It further clarified that High Courts cannot correct every error under this provision. Minor factual or legal mistakes do not justify intervention unless they result in a finding so unreasonable that no prudent person would arrive at such a conclusion.

Importantly, the Court reiterated that supervisory jurisdiction does not allow re-appreciation of evidence. The High Court cannot act as a court of first appeal or reassess facts to arrive at a different conclusion.

The case originated from a dispute involving a 2007 agreement between NICE and landowners in Bengaluru. NICE had acquired land for a road project and had agreed to provide either alternative land or compensation.

When alternative land was not provided, the landowners approached the executing court. The court fixed compensation at ₹1,000 per square foot based on applicable guidelines.

However, the High Court reduced this amount to ₹500 per square foot while exercising powers under Article 227. This decision was challenged before the Supreme Court.

The Supreme Court set aside the High Court’s ruling and restored the executing court’s decision. It held that the High Court had exceeded its jurisdiction by reassessing the compensation without any jurisdictional error in the original decision.

The judgment emphasised that substituting a reasonable decision with another merely because of disagreement is impermissible under Article 227. The High Court, in doing so, effectively acted as an appellate court.

The Court concluded that by adopting an alternative view on merits, the High Court had gone beyond the narrow scope of supervisory review. As a result, the appeal was allowed.

This ruling reinforces the principle that Article 227 is meant for maintaining judicial discipline and correcting jurisdictional errors, not for re-examining the merits of a case.