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Some matters may be assailed by quo warranto in a direct, rather than a collateral, attack. Other matters are properly assailed by collateral attack, rather than quo warranto proceedings; and, quo warranto itself may employed as a method of collateral attack.

Quo warranto is not a writ of correction or review. It is not an alternative for mandamus or injunction, or for an appeal or writ of error. On an appeal, the appellant may be permitted to introduce extrinsic evidence of the judgment in a quo warranto proceeding. Quo warranto cannot be used to force a rightful possessor of the office to do anything."

39- In the case of Hanuman Foundries Ltd. (supra) their Lordships of Supreme Court held that the writ of quo warranto is a direct attack which is merely collateral. Their Lordships have relied upon Halsbury's Laws of England (supra) and held that the office must be a public office and the court must be satisfied that the person proceeded against, has been in actual possession of the office. The principle laid down in the case of University of Mysore (supra) and in the case of Ghulam Qadir (supra), the question with regard to locus has been dealt with by Hon'ble Supreme Court and it is held that the right under Article 226 of the Constitution of India may be enforced only by the aggrieved person ordinarily, but even then in appropriate cases, the court may permit by adopting liberal approach.