Supreme Court limits a Letters Patent Bench's power to reopen a writ court's findings under Article 226

The Supreme Court has restored a Madras High Court writ court's order quashing the dismissal of R. Saravanan, a Deputy Registrar of Periyar University, after a Division Bench had reversed that order on an intra-court appeal under Clause 15 of the Letters Patent of the Madras High Court. The case turned on how far a Letters Patent Bench may interfere with a decision rendered by a Single Judge exercising writ jurisdiction under Article 226 of the Constitution. The Court held that while a Letters Patent Bench is, in principle, entitled to review even findings of fact as an appellate court, that jurisdiction is not unfettered: it may reopen a factual finding only where the finding is demonstrably erroneous, with a glaring mistake on the face of the record that bears on the merits, and it must give due weight to the writ court's exercise of discretion.

Where the writ court's decision is just, reasonable, in furtherance of equity and good conscience, and not against public policy, a Letters Patent Bench cannot substitute its own view merely because it would have decided differently. Applying this standard, the Court found that the Division Bench had interfered with a well-reasoned writ-court decision without any cogent or justifiable ground, set aside its judgment, and restored the order quashing Saravanan's removal from service.