Absence statutory power review railways act prevents recall arbitral awards

The Railways Act, 1989 and the Land Acquisition (Special Railway Projects) Rules, 2016 do not confer any power of review upon competent authorities or statutory arbitrators. In the absence of explicit statutory provisions authorizing administrative or quasi-judicial review, authorities lack jurisdiction to recall, modify, or keep in abeyance final arbitral awards. Quasi-judicial bodies created under specialized statutory frameworks possess only those powers explicitly granted by parliament, excluding inherent powers of administrative review. Once a statutory arbitrator renders an award determining enhanced compensation, the competent authority cannot unilaterally keep the disbursement in abeyance based on administrative inquiry reports. Executive orders attempting to recall or suspend statutory arbitral awards without explicit statutory authority are ultra vires and legally unsustainable. The power to correct or set aside statutory arbitral awards resides exclusively in competent judicial forums exercising prescribed appellate or supervisory jurisdiction. Consequently, administrative orders recalling or suspending arbitral awards passed under railway land acquisition rules must be set aside for total lack of jurisdiction. (Niraj Jain v. Competent Authority-cum-Additional Collector, Jagdalpur & Ors. | 2026 INSC 86)