This landmark case arose from a batch of writ petitions challenging the constitutional validity of Article 323A and 323B of the Constitution, which provide for the establishment of administrative tribunals. These tribunals were empowered to adjudicate disputes relating to various matters, including service matters, tax matters, and industrial disputes. The petitioners argued that these articles, and the consequent establishment of tribunals, effectively ousted the jurisdiction of the High Courts and the Supreme Court under Articles 226/227 and 32 respectively, thereby undermining the basic structure of the Constitution. They contended that the power of judicial review, a fundamental aspect of the basic structure, was being eroded by these tribunals. Prior to this case, the tribunals had been given the power to directly hear cases, with appeals lying only to the Supreme Court. This meant that the High Courts were bypassed entirely.

Issues:

The central issue before the Supreme Court was whether the provisions of Articles 323A and 323B, which excluded the jurisdiction of the High Courts in certain matters and provided for appeals from the tribunals directly to the Supreme Court, were constitutionally valid. The core question was whether this exclusion of High Court jurisdiction was compatible with the principle of judicial review, considered a basic feature of the Indian Constitution. The petitioners specifically challenged the power of the tribunals to act as the initial adjudicatory body for many cases, effectively removing the High Courts' power of superintendence and review. This raised concerns about access to justice, the quality of adjudication, and the potential for executive influence over tribunal decisions.

Analysis:

The Supreme Court, after considering the arguments, upheld the constitutional validity of Articles 323A and 323B. However, it significantly altered the appellate structure. The Court recognized the need for specialized tribunals to handle complex matters efficiently. However, it also emphasized the importance of preserving the power of judicial review vested in the High Courts. The Court held that the power of judicial review under Articles 226 and 227 is a basic feature of the Constitution and cannot be completely taken away. It reasoned that while tribunals could be created to deal with specific matters, the High Courts must retain the power of judicial review over the decisions of these tribunals.

The Court struck down the provision that allowed direct appeals from the tribunals to the Supreme Court. It held that appeals from the tribunals would lie to the Division Bench of the respective High Court. This ensured that the High Courts would continue to exercise superintendence over the tribunals and provide an essential layer of judicial scrutiny. The Court felt that bypassing the High Courts entirely would dilute the power of judicial review and affect the balance of power within the judicial system. The judgment emphasized the importance of maintaining the High Courts as effective guardians of fundamental rights and interpreters of the law.

The Court clarified that the jurisdiction of the Supreme Court under Article 32 (relating to enforcement of fundamental rights) would remain unaffected. It also clarified that the High Courts would continue to have the power to issue writs of certiorari to the tribunals. This ensured that the tribunals functioned within the bounds of the law and did not transgress their jurisdiction.

Conclusion:

The L. Chandra Kumar case is a landmark judgment that balances the need for specialized tribunals with the imperative of preserving the power of judicial review. The Court upheld the constitutional validity of Articles 323A and 323B but mandated that appeals from tribunals would lie to the High Courts, not directly to the Supreme Court. This modification ensured that the High Courts retained their power of judicial review over tribunal decisions, safeguarding the basic structure of the Constitution. The judgment established the principle that while tribunals can play a vital role in efficient adjudication, they cannot supplant the constitutional role of the High Courts in upholding the rule of law and protecting fundamental rights. It reinforced the importance of judicial review as a fundamental aspect of the Indian constitutional framework. This case is crucial in understanding the relationship between tribunals, High Courts, and the Supreme Court, and it continues to be a significant precedent in administrative law.