Supreme Court Rules: High Courts Cannot Re-Appreciate Evidence Under Article 227 Jurisdiction

IntroductionThe Supreme Court of India reiterated that High Courts cannot act as appellate courts while exercising powers under Article 227 of the Constitution. The Court clarified that supervisory jurisdiction is limited and cannot be used to re-evaluate evidence or substitute findings of lower courts.

Case TitleNandi Infrastructure Corridor Enterprises Ltd. & Anr. v. B. Gurappa Naidu & Ors.

Legal IssueThe issue was whether a High Court, while exercising jurisdiction under Article 227 of the Constitution, can reassess evidence and modify findings of a subordinate court.

Case BackgroundThe dispute arose from a 2007 compromise between Nandi Infrastructure Corridor Enterprises (NICE) and landowners in Bengaluru. NICE acquired part of the land for a road project and agreed to provide alternate land or compensation based on government guideline value.When alternate land was not provided, the landowners approached the executing court for compensation. The executing court fixed the compensation at ₹1,000 per square foot.The High Court later reduced this amount to ₹500 per square foot while exercising its powers under Article 227. This led to an appeal before the Supreme Court.

Court’s Ruling

A bench comprising Justice Aravind Kumar and Justice BV Anjaria allowed the appeal and set aside the High Court’s decision.The Court held that Article 227 grants only supervisory powers. It does not allow the High Court to act as an appellate authority. The Court emphasized that re-determining compensation amounts amounts to reassessment of facts, which is not permitted under Article 227.

Principles Laid DownThe Court clarified that supervisory jurisdiction can be exercised only in limited situations. It applies when a subordinate court assumes jurisdiction without authority, abuses its jurisdiction, or refuses to exercise jurisdiction.The Court stated that High Courts cannot re-appreciate evidence or correct every factual or legal error. It also held that High Courts cannot substitute their own view merely because they disagree with the subordinate court’s findings.

Final OutcomeThe Supreme Court restored the executing court’s order fixing compensation at ₹1,000 per square foot. It held that the High Court had exceeded its jurisdiction by modifying the award.

ImplicationsThis judgment strengthens the limits on Article 227 jurisdiction. It ensures that High Courts do not interfere with factual findings unless there is a clear jurisdictional error.The ruling promotes judicial discipline and prevents misuse of supervisory powers as an appellate mechanism.

ConclusionThe decision reinforces that Article 227 is meant for supervision, not substitution. High Courts must respect the findings of subordinate courts unless there is a serious jurisdictional flaw.