Supreme Court: Letters Patent Bench cannot overturn writ Court order without clear error of law

The Supreme Court, by a two‑judge bench, allowed the appeal filed by R. Saravanan and set aside the judgment of the Madras High Court Division Bench sitting under the Letters Patent, thereby reinstating the order of the High Court exercising its writ jurisdiction under Article 226 which had restored the removal of the appellant, the Deputy Registrar of Periyar University.

The appellant had been removed from service following a domestic inquiry conducted by a one‑man commission. He challenged the removal before the High Court under Article 226, which upheld the removal. Subsequently, a Division Bench of the Madras High Court, invoking the Letters Patent clause, reversed the writ Court’s order on the ground that it arrived at a different factual conclusion.

The Supreme Court held that a Letters Patent Bench could not overturn a writ Court’s order unless there was a clear error of law or jurisdiction, and it could not re‑appreciate evidence or substitute its own view of fact. Clause 15 of the Letters Patent was interpreted as conferring appellate jurisdiction limited to questions of law and to factual errors that were perverse or unsupported by material. Accordingly, the Letters Patent judgment was set aside and no order as to costs was made.

Read the judgment and its head note on DLJ: R. Saravanan vs Periyar University Rep By Its Registrar (2026 INSC 1136).