Punjab & Haryana High Court: Civil Court Cannot Direct SDO to Decide Pending Application — Jurisdiction Limited to Matters Within Its Domain

Case Name: Manohari Devi and Another v. Pawan Kumar and Others
Date of Judgment: October 13, 2025
Citation: CR-5168-2025 (O&M)
Bench: Hon’ble Ms. Justice Mandeep Pannu

Held: The Punjab & Haryana High Court held that a Civil Court has no authority to issue directions to independent administrative or quasi-judicial authorities unless expressly empowered by law. Justice Mandeep Pannu ruled that the Civil Judge (Junior Division), Sirsa, exceeded her jurisdiction by directing the Sub-Divisional Officer (Civil), Sirsa, to decide an application pending before him. The Court observed that a Civil Court’s jurisdiction is confined to adjudicating matters within its own domain and cannot extend to administrative or quasi-judicial orders directed at statutory authorities.

Summary: The petitioners filed a revision under Article 227 of the Constitution challenging the order dated July 1, 2025, by which the Civil Judge (Junior Division), Sirsa, directed the SDO (Civil), Sirsa, to decide an application dated November 30, 2018, relating to allotment proceedings. The petitioners contended that such an order was without jurisdiction, as a Civil Court cannot command an independent administrative authority. The respondents argued that the petitioners’ application under Order VII Rule 11 CPC had already been decided, rendering that part of the revision infructuous. They, however, conceded that the Civil Judge had no power to direct the SDO to decide any pending application. Justice Mandeep Pannu agreed with the petitioners, holding that the Civil Court had acted beyond its jurisdiction by issuing administrative directions to another authority, which is impermissible in law.

Decision: The High Court partly allowed the revision petition. The direction issued by the Civil Judge (Junior Division), Sirsa, in order dated July 1, 2025, instructing the SDO (Civil), Sirsa, to decide the application dated November 30, 2018, was set aside. The portion of the petition concerning the application under Order VII Rule 11 CPC was dismissed as infructuous since that application had already been decided. The order of status quo dated January 19, 2023, was ordered to remain operative and unaffected.