In Brief
Municipal staff quarters allotted in the 1960s on a leave-and-license basis to retired employees' heirs were the subject of eviction proceedings by the Mumbai Municipal Corporation under the MMC Act. After extensive litigation spanning over a decade, the High Court ordered the Inquiry Officer to determine nine framed issues. The Supreme Court held that the High Court exceeded its supervisory jurisdiction by framing issues for a quasi-judicial authority. Orders of civil courts are amenable only to Article 227 review, not Article 226. The absence of regulations under Section 105H does not prevent eviction proceedings. Institutional bias cannot be presumed merely from the Inquiry Officer's employment by the Corporation. The Court set aside the High Court's order, directing the Inquiry Officer to conduct proceedings fairly, allow evidence, and independently decide issues based on natural justice.
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