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  • Dhavle, J.
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  • rights.11. Section 144
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  • Dhavle, J.
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  • rights.11. Section 144
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Smart Summary

Structured Summary of the Opinion — Revision against Orders under Section 144 CrPC

Factual and Procedural Background

This is an application in revision against orders passed under Section 144 of the Criminal Procedure Code by the Sub-divisional Magistrate (SDM), Bhabua, initially dated 2nd June 1941 (order recorded as being in force for two months) and subsequently renewed or re-passed on 28th August 1941 and confirmed on 8th September 1941. The District Magistrate (DM) of Shahabad considered an earlier revision application on 12th August 1941 and declined to interfere, and later (on 23rd September) again declined to reconsider the SDM's order.

The underlying factual dispute began when, on 21st April 1941, the first party (the complainant/opposite party before this Court) complained that the second party (the petitioners here) were building on plot No. 268 and that eaves and rainwater from that building would fall upon and damage the complainant's adjoining plot No. 267; an overseer measured the site and reported an encroachment. The SDM, being satisfied that a breach of the peace was imminent, issued notice and later ordered the second party to vacate a specific triangular portion, to remove a new wall described in the order, and to take steps to prevent eaves' water falling onto plot No. 267.

The second party denied encroachment, asserted that the wall had been rebuilt on old foundations and that the disputed open space belonged to them, and produced copies of a civil plaint served upon them (the first party had instituted a civil suit). Despite these contentions and the pendency of the civil suit, the SDM issued mandatory directions under S.144 and threatened prosecution for non-compliance. The second party's revision applications to the DM were dismissed or not entertained on the merits. The present Court reviews those orders under revision.

Legal Issues Presented

  1. Whether a Magistrate exercising jurisdiction under Section 144 CrPC may pass a mandatory order requiring demolition or removal of structures (i.e., an order of a positive, irreversible nature) as opposed to only issuing restrictive or temporary directions.
  2. Whether, given the pendency of a civil suit between the parties concerning title or right to the land/structure, the Magistrate should have refrained from deciding or giving operative effect to disputed civil rights by an order under Section 144 and instead left the dispute to the civil court.
  3. Whether orders passed under Section 144 were properly limited in time, and whether renewals/repetitions of S.144 orders were consistent with the statutory time-limits and purpose of that provision.

Arguments of the Parties

Second Party (Petitioners) — Principal Arguments

  • Denied any encroachment and asserted that the wall in question had been rebuilt on the foundations of an older wall.
  • Asserted that the entire open space between the two plots belonged to them (the second party).
  • Filed and relied on copies of the plaint of the first party (showing a civil suit pending) and argued that the Magistrate should not remove the wall under S.144 while the civil suit was pending.
  • Requested that the overseer who made the measurements be produced and be subject to examination/cross-examination to test the accuracy of the measurement.
  • Urged postponement of the SDM's order until the civil court decided the title/rights dispute.

First Party / Opposite Party — Principal Arguments (as appearing in the record)

  • Complained that the second party were building on plot No. 268 and that their eaves encroached on plot No. 267, causing rainwater to fall and damage the complainant's land.
  • Pursued a civil suit for removal of the alleged encroachment and served a plaint upon the second party; relied upon the Magistrate's power to prevent breach of the peace to obtain immediate preventive relief.
  • Before the Court, a learned advocate for the opposite party cited a reported case (20 P.L.T. 850) to support the contention that, in certain factual circumstances, a Magistrate could order removal of an obstruction (a bundh) affecting the flow of water by virtue of the power to “take certain order with property in his possession.”

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
A.I.R. 1935 Pat. 224 Establishes that the statutory period for an order under S.144 runs from the date on which the first notice is issued. Cited to show the SDM erred in computing the two-month period; the Court held the SDM misunderstood the commencement of the statutory period.
18 W.R. 47 (Cr.) Holds that orders under S.144 may validly interfere with private rights of enjoyment of property in the public interest (subject to limitations). Used to acknowledge that S.144 can interfere with private rights but to emphasize that such jurisdiction must be exercised with care and within statutory limits.
5 C.W.N. 329 Later case supporting the proposition that S.144 orders can interfere with private rights in the public interest. Reinforces the Court's point that interference is permissible but must be temporary and carefully exercised.
58 Cal. 1037 Bankin, C.J. held that the expression in S.144 does not empower Magistrates to make a positive order requiring a person to do particular things. Relied upon to support the conclusion that S.144 does not authorize mandatory/positive orders (such as a compulsory demolition order) beyond temporary restrictive measures.
19 P.L.T. 620 Expresses that S.144 does not authorize the passing of mandatory orders; the magistrate may only pass restrictive orders and cannot dispossess a party. Applied as authority that S.144 should not be used to dispossess or to require affirmative acts that have an irrevocable effect.
13 W.R. 72 (Cr.) Holds that a Magistrate has no power to issue orders which are by their very nature irrevocable (example: order to cut down a large quantity of trees). Used to illustrate the principle that S.144 cannot be used to issue irrevocable or permanent orders.
32 Cal. 154 Case holding limits on magistrates' power to issue certain kinds of orders (context similar: removal of structures). Cited alongside other authorities to show established limits to the magistrate's powers under S.144.
A.I.R. 1929 Pat. 523 Holds it beyond a Magistrate's jurisdiction under S.144 to order removal of a bundh erected by persons (i.e., to order positive demolition). Relied on to support the proposition that the Magistrate exceeded jurisdiction by ordering demolition of the wall under S.144.
20 P.L.T. 850 Reported to hold (on its facts) that where a bundh was erected to obstruct water on land not in the party's possession, the Magistrate directed cutting of the bundh by virtue of power to “take certain order with property in his possession.” The Court examined and distinguished this case on its facts and found it did not support a general proposition that S.144 permits demolition orders of the kind made by the SDM in the present case.
I.L.R. (1937) 2 Cal. 475 Apparently cited in support of the view that a Magistrate may pass mandatory orders regarding property in possession (as relied on in 20 P.L.T. 850). The Court noted this authority was relied upon by the learned Judge in 20 P.L.T. 850 but expressed reservation as to the breadth of that view and did not treat it as controlling for the present facts.
27 Cal. 918 Holds that a Magistrate deciding disputes (for example, family share disputes) under S.144 exceeded jurisdiction—orders were unauthorized especially when not limited to two months and when civil rights were being determined. Used as an example of the impermissibility of assuming civil court functions under S.144; supports setting aside the SDM's orders that effectively decided title/possession.
8 C.W.N. 376 Another authority demonstrating limits on magistrates' powers in civil-type disputes under S.144. Cited to reinforce the principle that S.144 cannot be used to decide disputes properly triable in civil courts.
A.I.R. 1935 Pat. 145 Indicates that the propriety of an order whereby a Magistrate assumes the function of the Civil Court (practically amounting to ejectment on title grounds) may be questioned even if technically justified by an apprehension of breach of the peace. Applied to show that the SDM's order, which had the practical effect of ejectment/demolition on title-like grounds, was open to challenge for usurping civil jurisdiction.
7 C.W.N. 140 States that a Magistrate has no jurisdiction under S.144 to pass an order not limited in time or which purports to be a perpetual injunction. Used to demonstrate that renewal or repetition of S.144 orders so as to achieve a permanent effect is impermissible without executive sanction; supports the conclusion that the renewals in the present case were improper.
11 C.W.N. 791 Comments that renewals of S.144 orders would operate to extend an injunction under S.144 without sanction of the local Government (thus impermissible). Relied upon to show that the practice of renewing S.144 orders to effect longer-term or permanent relief is not permitted.
A.I.R. 1917 Pat. 154 Authorities (Roe and Jwala Prasad, JJs.) pointing out that renewals of S.144 orders would effectively extend injunctions without proper sanction. Supported the Court's view that repetition/renewal of the SDM's S.144 order to achieve sustained effect was improper.

Court's Reasoning and Analysis

The Court proceeded in two linked strands: (A) analysis of errors of fact and procedure in the lower Courts' handling of the matter, and (B) legal analysis of the scope of Section 144 CrPC and the limits of magistrates' powers under that section.

(A) Errors in lower courts' approach and chronology:

  • The SDM misconstrued the computation of the two-month period under S.144 by not treating its commencement as the date of the first notice (contrary to the authority cited: A.I.R. 1935 Pat. 224).
  • The SDM misattributed the initiation of the civil suit, thinking it had been brought by the petitioners, whereas the plaint clearly showed the opposite party had filed the suit; the petitioners had copies of the plaint served on them, which the SDM and later the DM wrongly treated as insufficient unless certified copies were filed.
  • Evidence in the record (affidavit and plaint) established that the civil suit had been filed before the SDM's decisive dealing on 2nd June 1941, and that the wall and thatching pre-dated the SDM's order; on these facts the SDM ought to have respected the limits of his jurisdiction and left contested title/possession issues to the civil court.

(B) Legal analysis of Section 144 CrPC and application to facts:

  • The Court emphasised the legislative design of Chapter XI (S.144) as providing for temporary orders in urgent cases of nuisance or apprehended danger; urgency and temporariness are essential.
  • Sub-section (6) of S.144 caps the duration of such orders to two months (except in narrowly specified exceptional circumstances). The temporal limit implies that orders under S.144 must not be irrevocable or permanent in nature.
  • While S.144 may in proper cases interfere with private rights in the general interest (as several authorities show), the jurisdiction must be exercised cautiously and interference with private rights should be minimized and confined within statutory limitations.
  • The statutory power to “direct any person to abstain from a certain act or to take certain order with certain property in his possession or under his management” must be interpreted in light of the temporariness requirement; it does not authorize, in general, positive, irrevocable orders that decide disputed civil rights or effectively dispossess a party.
  • Past decisions (cited by the Court) have held that S.144 does not empower magistrates to order affirmative acts such as demolition or cutting down trees where the order would be irrevocable in nature.
  • The SDM in this case ordered demolition/removal of a wall and required vacating a portion of land on pain of prosecution. The Court found that this amounted to deciding contested civil rights and ordering an irreversible act, which is beyond the proper scope of S.144.
  • The Court considered and distinguished the authority relied on by the opposite party (20 P.L.T. 850), finding that the facts and context of that decision were materially different and did not support a general power to issue demolition orders of the kind made by the SDM here.
  • The SDM also attempted to renew or re-pass orders in such a way as to extend their practical operation beyond the statutory time limits, a practice the authorities disallow; the SDM's inconsistent time computations and renewals demonstrated misunderstanding or misapplication of S.144.
  • Because a civil suit between the parties was pending and the contested acts and rights related to title and possession, the Court concluded the SDM should not have used S.144 to usurp the jurisdiction of the civil court or to give permanent effect to his view of title.

Holding and Implications

Holding: The revision application is allowed. The Court held that the orders of the Sub-divisional Magistrate (including the renewal on 28th August and the confirmation on 8th September) were entirely unjustified and must be set aside. The earlier order of 2nd June was time-expired, and the subsequent renewals/confirmations are vacated to prevent an unjustifiable prosecution of the petitioners for alleged disobedience.

Implications:

  • Direct effect on the parties: The SDM's mandatory directions to remove the wall and to vacate the specified triangular portion (and any threat of prosecution for not complying with those directions) are set aside in revision; the petitioners are protected from prosecution based on those orders.
  • Legal/practical guidance reiterated by the Court: Section 144 CrPC is for temporary, urgent prevention of nuisance or apprehended danger and must not be used to decide civil rights of title or to issue irrevocable, mandatory demolition/dispossession orders. Renewals or repetitions of S.144 orders cannot be used to circumvent the statutory temporal limit or to effect a de facto perpetual injunction without proper authority.
  • The Court did not claim to establish a new rule beyond the cited authorities but applied settled principles to restrain the SDM's overreach; in that sense no novel precedent was announced, but the order reinforces established limits on the use of S.144 against disputes properly triable in civil courts.
G.N/R.K

Disposition: Application allowed.

Show full summary ...

    Ram Narain Sah And Another v. Parmeshar Prasad Sah And Others Opposite Party.

    1. This is an application in revision against an order under Section 144 of the Cr PC, passed by the Sub-divisional Magistrate of Bhabua on 8th September 1941. On 23rd September, the District Magistrate of Shahabad who was moved in revision against the order of the Sub-divisional Magistrate declined to interfere as he had already considered the merits of the case on a previous occasion and saw no grounds for reconsideration. On 21st April 1941, the first party before the Sub-divisional Magistrate (being the opposite party in this Court) complained to the Magistrate that the second party (the petitioners here) were building on their plot No. 268, and that their eaves were encroaching on the complainant's plot (No. 267) which adjoined and that their rain water would fall on the complainants' land and cause damage. The Magistrate recorded that he was satisfied that a danger of breach of the peace was imminent and issued notice under S. 144(2) against Ram Narain Sahu of the second party “to refrain from further building his house on plot No. 268 for a period of two months… Work must stop and he may show cause against the order by 9th May 1941.”

    2. The second party denied any encroachment and the Magistrate had a measurement made by an overseer. The overseer reported an encroachment, and the Magistrate gave time to the parties to file further written statements. The second party again denied any encroachment and said that the wall objected to had been already rebuilt on the foundations of an old wall, that the entire open space between the two plots belonged to the second party, and that the first party had already brought a civil suit for the removal of the alleged encroachment. They also filed the mosanna or copy of the plaint of the first party served upon them and urged that the notice issued against them be cancelled. The Sub-divisional Magistrate proceeded on the footing that neither side had dared to challenge the overseer's report, and in the view that “immediate prevention is desirable in order to prevent annoyance to the first party and disturbance of the public tranquillity.”

    3. He ordered the second party under S. 144 “to take the following order regarding the property in his possession. He will immediately vacate a triangular portion measuring 2 feet 9 inches at the base and 18 feet long, which represents his encroachment on plot No. 267, and he will immediately remove the new wall which sits on this encroachment and occupies an area 1 feet 3 inches at the base and 10 feet long, and he will immediately take such steps with regard to his property on plot No. 268 as to prevent a single drop of his eaves' water falling on to plot No. 267.”

    4. He warned the second party that failure to obey the order by 15th June 1941 would “result in stern action from the Court,” and curiously enough, added that the order would remain in force for two months, saying that “this will leave a margin of 1½ months for the parties to settle down to the position determined by me.”

    5. This was on 2nd June 1941. The second party at once moved the District Magistrate in revision, and on 12th August 1941, the District Magistrate saw no reason to interfere, as the order of the Magistrate was substantially based on the report of the overseer which was not challenged by either party, and there was “nothing perverse in the order of the learned lower Court who has given plausible reason in support of his findings.”

    6. On 28th August, the first party moved the Sub-divisional Magistrate on the ground that the second party had not yet removed the encroachment. The Sub-divisional Magistrate referred to the fact that the District Magistrate had dismissed the petition in revision filed by the second party, and directed that a copy of his order of 2nd June, be served “at once for compliance” on the second party. “As the old period expired on 2nd August 1941, the Magistrate added “the same order is passed again under Section 144 of the Cr PC, as I am satisfied that there is serious apprehension of breach of peace and immediate prevention is necessary, for a period of one month commencing from to-day, the former order not yet being complied with by second party.”

    7. On 8th September, the second party applied to the Magistrate, urging “that the disputed wall existed before the proceedings started and it cannot be removed under Section 144 of the Cr PC, especially when a civil suit is pending to decide the issue” that “at least the overseer should be examined and cross-examined to know the reality of his measurement and its accuracy,” and that the Magistrate's order be postponed till the decision of the civil Court. The Sub divisional Magistrate rejected this petition, relying on the fact that the District Magistrate had found nothing perverse in his previous order. He considered that the words of Section 144 of the Cr PC, “to take certain order with certain property in his possession or under his management” were quite clear, and that his order under S. 144 “was nothing else but this.” In his view S. 144, of which “the essence” is “time and urgency,” did not contemplate that the Magistrate should await the decision of the civil Court:

    “Finally, the second party have not even filed certified copy to show that he has brought any civil suit with regard to this matter.”

    8. The application of the second party was therefore rejected, and he was given “time until 22nd September 1941 to comply with my order, failing which he will be liable to the penalty for disobeying an order under Section 144 of the Cr PC.”

    9. This is the order now challenged. An application against it was rejected by the District Magistrate who declined to reconsider the merits, and though a certified copy of the plaint in Title Suit No. 61 of 1941 dated 8th May 1941, had been filed before him and it appeared from the order of the Munsif dated 25th August 1941, that the case was shortly due to be heard, he said that it was open to the petitioners to move the lower Court for a review and for stay of the order of removal of the wall pending the decision of the civil Court.

    10. That the lower Courts were in error at point after point seems obvious. The Sub-divisional Magistrate, for instance, took it that the period of two months during which his order was to remain in force ran from 2nd June 1941, but it is settled law that the period runs from the date on which the first notice is issued: see A.I.R 1935 Pat. 224.1 The Sub-divisional Magistrate also thought that it was the petitioners that had brought the civil suit, while it is clear that the suit was brought by the other side. The lower Courts both thought that it was necessary for the petitioners to file a certified copy of the plaint, but this was surely unnecessary when the petitioners filed the copies of the plaint that had been served upon them together with the summonses as defendants in the suit. In the affidavit before me it is said that the opposite party filed their suit on 5th May 1941, and this allegation is not denied, so that it must be taken that the opposite party had filed their suit before the Magistrate dealt with the matter on 2nd June. According to para. 12 of the plaint the wall was raised on 5th April 1941, and the thatching was completed on the 21st of that month, dates which make it perfectly dear that the Magistrate ought, with a due regard to the nature and limits of his jurisdiction in such matters, to have left to the civil Court the decision of their disputed rights.

    11. Section 144 of the Cr PC, which constitutes Chap. 11 provides for “Temporary Orders in Urgent Cases of Nuisance or Apprehended Danger” (to quote from the heading of the chapter), while Chap. 12 provides for magisterial action in “disputes as to immovable property.” The urgency of a case of nuisance or apprehended danger is essential to its treatment under S. 144, and the orders to be passed under the section must be of a temporary nature as is shown clearly by sub-s. (6) of the section providing that no order under this section shall remain in force for more than two months from the making thereof; unless, in cases of danger to human life, health or safety, or a likelihood of a not or an affray, the Provincial Government by notification in the Official Gazette otherwise directs. Such orders are passed in the general interests of society and may validly interfere, within the limitations laid down, with private rights of enjoyment of property, as was held by the Full Bench in 18 W.R 47 (Cr.)2 and in later eases such as 5 C.W.N 329.3 There is therefore all the more reason why the jurisdiction under S. 144 ought to be exercised carefully and interference with private rights reduced to a minimum and regulated by a full observance of the limitations imposed by the section itself. The Magistrate is authorized by the section in proper cases to “direct any person to abstain from a certain act or to take certain order with certain property in his possession or under his management.” The abstention from certain acts must obviously not be carried too far. In 58 Cal. 1037,4 Bankin, C.J held that the expression does not empower Magistrates to make a positive order requiring a person to do particular things. This is sometimes expressed as was done by Chatterji, J. in 19 P.L.T 620,5 by saying that S. 144 does not authorize the passing of any mandatory order—he may only pass a restrictive order and cannot, for instance, as in that case, order a party to remove a fence erected by him to enclose property marked off by boundary pillars erected by himself, nor use s. 144 to dispossess such party. Any order under s. 144, whether it directs a party to abstain from a certain act or to take certain order with certain property in his possession etc. must be of a temporary character, which means that it must not be irrevocable in its nature or partake of the character of a perpetual injunction. Even before the limit of two months was introduced by the Criminal Pro. Code of 1882 it was held in 13 W.R 72 Cr.6 that the Magistrate has no power “to issue any order which is by its very nature irrevocable,” such as “an order to cut down a large quantity of trees”: see also 32 Cal. 154,7 and A.I.R 1929 Pat. 523,8 in which Fazal Ali, J. (with the concurrence of Courtney-Terrell, C.J) observed that it is well-established law that it is beyond the jurisdiction of a Magistrate to pass an order under s. 144 requiring people who had erected a bundh to remove it.

    12. In the present case the Magistrate required the petitioners to remove a wall erected by them, and the learned advocate for the opposite party has endeavoured to support this by citing 20 P.L.T 850,9 decided by Agarwala, J. The facts of this last case, however, do not appear very clearly from the report, and the placitum is not altogether in accordance with what the learned Judge probably intended to decide. “Where a party erected a bundh on the land of another,” runs the placitum, “to obstruct the flow of water and the Magistrate directed the party in possession to cut the bundh,” the Magistrate was held empowered by reason of the words “to take certain order with property in his possession etc.” “to pass a mandatory order on persons in possession of property.” It appears from one portion of the judgment that the bundh was erected by the second party, in anticipation of and in order to frustrate an order under S. 144 “on land which was not in their possession and to which they had no right whatsoever.” It was, moreover, not the second party that was required to remove the bundh but the first party that was permitted to remove the obstruction to the flow of water, the local Police being directed to assist in the removal. The decision is thus easily distinguishable on the facts, and as to the view of the learned Judge regarding the authority of a Magistrate to pass a mandatory order on persons in possession of property, which was rested on I.L.R (1937) 2 Cal. 475,10 it seems to me, with all respect, that the words “to take certain order etc.” must no less than the previous expression “to abstain from a certain act,” be interpreted in the light of the provisions of sub-s. (6) which limit the operation of the order to a maximum of two months and by necessary implication exclude an order, such as an order demolishing a wall, which is irrevocable in its nature. The Magistrate's jurisdiction under s. 144 is not a jurisdiction to assume the functions of the Civil Court, though he can decide questions of possession and of rights of user by appropriate proceedings under Chap. 12, Code of Criminal Procedure. In 27 Cal. 918,11 the Magistrate in fact decided a dispute between members of a family regarding their shares under S. 144, and it was held that his order was unauthorized, not merely because it was not passed in any emergency, but also because its operation was not limited to two months, and because he had taken it upon himself to decide questions of fact on Mahomedan law so as to satisfy himself as to what were the actual rights of the parties to the lands in dispute: see also 8 C.W.N 376.12 In the present case the Magistrate concluded from the measurements made by the overseer that the petitioners had encroached on the plot of the opposite party, but in doing so, he paid no attention to the allegation of the petitioners that they had only rebuilt the wall on the foundations of an older wall, and made use of s. 144 to give effect to his view of the title by requiring the petitioners to demolish the wall on pain of prosecution. It was held in A.I.R 1935 Pat. 145,13 that the propriety of the order whereby the Magistrate assumes the function of the Civil Court and makes an order which practically amounts to an order of ejectment on grounds of title may be questioned, though he may be technically justified by the fact that he records his apprehension of a breach of the peace, by which it was to be understood that he apprehended an affray at the door of the shop when one party desired that the door should be opened and the other party desired that it should not. The Magistrate has no jurisdiction under s. 144 to pass an order which “is not limited in time, but on the face of it purports to be of the nature of a perpetual injunction”: 7 C.W.N 140,14 where it was also pointed out that he had no jurisdiction to make an order for the renewal of the original order (see also 11 C.W.N 7915 and A.I.R 1917 Pat. 154,16 where Roe and Jwala Prasad, JJ. pointed out that such renewals would operate “to extend an injunction under s. 144 without the sanction of the local Government.”). I do not consider it necessary to refer the lower Courts to more recent decisions of this Court in which it has been pointed out that it is not open to a Magistrate to evade sub-s. (6) of S. 144 by repeating orders under S. 144. The Sub-Divisional Magistrate on the present occasion did refer specifically to the limit of two months under sub-s. (6), without apparently understanding what it means, for it is difficult to see why on 2nd June he should have required the second party to remove the new wall by 15th June and yet say that his order was to remain in force for two months, or why on 28th August he should renew his order for one month and on 8th September give the petitioners time till 22nd September to comply with his order. The District Magistrate also failed to see that an order to demolish a wall, if carried out, implies an order the operation of which would not be limited to two months; but this is far less surprising than his failure to see that with the civil suit already instituted by the opposite party the Magistrate should not have wasted his time by usurping the jurisdiction of the Civil Court (which incidentally would not have allowed execution before decree) and abusing in more than one respect the jurisdiction given to him by law. The orders of the Sub-Divisional Magistrate, though repeatedly approved by the District Magistrate, were entirely unjustified. The order of 2nd June is time expired; but its renewal on 28th August which was confirmed by the order of 8th September must be set aside, if only to prevent an unjustifiable prosecution of the petitioner for disobedience. The application in revision is accordingly allowed.

    G.N/R.K

    13. Application allowed.

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    Comments

    Ram Narain Sah And Another v. Parmeshar Prasad Sah And Others Opposite Party.
    (Mar 13, 1942)