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Issues Involved:
1. Whether the Tribunal constituted under the West Bengal Land Reforms and Tenancy Tribunal Act, 1997 is a Tribunal within the meaning of Article 323B(1)(d) of the Constitution of India. 2. Whether the jurisdiction, power, and authority of the Tribunal specified in Sections 5, 6, 7, and 8 of the Act are ultra vires the Constitution of India. 3. Whether the provision of the Act, by which all pending matters, proceedings, cases, and appeals before the High Court stood transferred to the Tribunal under Section 9, is ultra vires the Constitution. Detailed Analysis: 1. Tribunal under Article 323B(1)(d): The High Court initially rejected the contention that the Tribunal constituted under the Act was not a Tribunal within the meaning of Article 323B(1)(d). The Supreme Court upheld this decision, noting that the Tribunal was validly constituted under Article 323B for adjudicating disputes related to land reforms and tenancy. The Court emphasized that the Tribunal's scope, as defined in the Act, falls within the ambit of "land reforms" under Article 323B(2)(d), which is not limited to agrarian reforms but includes a broader range of land-related issues. 2. Jurisdiction, Power, and Authority of the Tribunal: The High Court had struck down Sections 5, 6, 7, and 8 of the Act, holding that they abridged the High Court's power of judicial review under Articles 226 and 227, violating the basic structure of the Constitution. The Supreme Court, however, disagreed with this view. It referred to the precedent set in L. Chandra Kumar v. Union of India, which held that while the jurisdiction of the High Courts under Articles 226/227 and the Supreme Court under Article 32 cannot be entirely excluded, Tribunals can perform a supplementary role. The Supreme Court concluded that the High Court's findings were inconsistent with the binding precedent set by L. Chandra Kumar, which is considered 'law declared' under Article 141 of the Constitution. 3. Transfer of Pending Matters to the Tribunal: The High Court had also declared Section 9 of the Act, which provided for the transfer of all pending matters from the High Court to the Tribunal, as ultra vires. The Supreme Court overturned this decision, reiterating that the Tribunal could act as the court of first instance for the specified matters, with the High Court retaining its writ jurisdiction for judicial review. This arrangement does not violate the basic structure of the Constitution, as it preserves the High Court's supervisory role while allowing the Tribunal to handle initial adjudications. Conclusion: The Supreme Court allowed the appeal, setting aside the High Court's judgment. It upheld the constitutional validity of the West Bengal Land Reforms and Tenancy Tribunal Act, 1997, confirming that the Tribunal constituted under the Act is within the meaning of Article 323B of the Constitution. The Supreme Court emphasized that the Tribunal's role is supplementary to the High Court's writ jurisdiction, aligning with the principles established in L. Chandra Kumar. There was no order as to costs.
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