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15. However, the moot question which needs determination is - whether the bar to Court's interference in electoral matters contained in Article 243-O operates qua the High Court's power of judicial review under Article 226. A reading of the plain language of Article 243-O makes it clear that the ambit and reach of the bar contained therein is very wide and pervasive. The non-obstante clause contained in that article excludes all other provisions of the Constitution, which necessarily include Article 226. It lays down that the validity of any law relating to the delimitation of constituencies or the allotment of seats to such constituencies made or purporting to be made under Article 243-K shall not be called in question in any Court. It also declares that no election to any Panchayat shall be called in question except by an election petition presented to such authority and in such manner as provided for by or under any law made by the Legislature of a State. In other words, the power of the judicial review conferred upon the High Courts under Article 226 of the Constitution of India is not available to an aggrieved person until after the adjudication of the election dispute by an authority constituted under the law enacted by the Legislature of the concerned State. To put it differently, any challenge to the election or any election dispute can be adjudicated in the first instance only by an authority constituted by or under any law made by the Legislature of a State and not otherwise. The High Court can entertain writ petition against an adjudicatory order made by the Tribunal etc. constituted under the State Legislation, but cannot entertain a petition directly filed under Article 226 of the Constitution questioning the law relating to delimitation of constituencies or the allotment of seats or election to any Panchayat. The reason why the Parliament did not want any judicial intervention in the process of election is clearly discernible from the scheme of various provisions contained in Part DC While making the Panchayats as units of self-Govemment, the Parliament also ensured that they are controlled by democratically elected bodies having a fixed tenure of five years. If the word "shall" appearing in Clause (1) of Article 243-E is read in conjunction with the expression "no longer" used in that clause and Sections 13(1) and 14(3) of the 1994 Act, it becomes clear that the elected body of Panchayat cannot continue in office for a period of more than five years. This interpretation is amply supported by the mandatory nature of the provision contained in Clause (3) of Article 243-E, which requires that election to constitute a Panchayat shall be completed before the expiry of its duration of five years. These provisions are also reflective of the legislative intendment that the electorates of the Panchayats should be able to exercise their franchise to choose the candidates of their choice at the end of five years period, if not before. While enacting Clause (3) of Article 243-E, which, as mentioned above, mandates that election to constitute a Panchayat shall be completed before expiry of its duration of five years, the Parliament must have taken into consideration that the provisions contained in various statutes for appointment of administrative and executive officers to manage the affairs of the local bodies in urban as well as rural areas at the end of the term of the elected bodies and the fact that these provisions are generally misused and efforts are made by the interested parties and persons to deprive the people of their right to choose their representatives. The Parliament must also have taken note of the fact that process of election to various bodies including Panchayats, which are intended to be units of self-Government, is frustrated by judicial interventions at various stages like delimitation of constituencies, issuance of notification for holding election, preparation and publication of the electoral rolls, filing of nomination papers, actual poll, counting of votes and declaration of result. Therefore, with a view to ensure that the elections to the Panchayats, which have been declared as units of self-Government, are held without interruption on account of intermediate/ interlocutory judicial interventions, the Parliament designedly enacted Article 243-O and introduced a complete bar to Courts' interference in the electoral matters and also incorporated non-obstante clause which operates qua all other provisions contained in the Constitution. If the Parliament intended to exclude Article 226 from the purview of the non-obstante clause contained in Article 243-O, then the language of that Article would have been like that of Articles 116, 120, 128, 133(2), (3), 136, 145, 170(1), 196, 197(3), 204(3), 206, 210, 224-A, 226(1), 231(1), 239(2), 243-M(1), 243-N, 243-ZC, 246(1) and (2), 247, 249(1), 250(1), 253, 266(1), 271, 276(1), 301, 303(1), 304, 312(1), 317(1), 330(3), 331, 332(B), 333, 334, 343(1), 345, 348(1), (2), 376(1) and 378-A. The non-obstante clauses contained in these Articles have limited operation. For example, non-obstante clause contained in Article 116 operates against the provisions contained in Chapter II of Part IV. The non-obstante clause contained in Article 120 operates against the provisions contained in Part XVII. Similar is the ambit and scope of the non-obstante clauses contained in the remaining articles of this family. As against this, the non-obstante clauses contained in Articles 243-O, 243-ZG, 244-A, 258(1), 258-A, 262(2), 329, 363, 363-A, 368, 369, 371(2), 371-A(1), (2), 371-B, 371-C, 371-F, 371-H and 371-I are very wide. The expression used in these articles is "notwithstanding anything contained in this Constitution". This means that the provisions contained therein operate against all other articles of the Constitution. If the non-obstante clause contained in Article 243-O and similar clause contained in Article 243-ZG is interpreted in the backdrop of the fact that the Parliament did not want intermediary/interlocutory judicial interventions in the process of election which constitutes an integral part of the democratic set up of our country, it becomes clear that the High Court's power of judicial review under Article 226 of the Constitution is postponed in the matters involving challenge to delimitation of constituencies or allotment of seats or election to Panchayats until after completion of the process of election and adjudication of election dispute by an adjudicatory forum created under the law enacted by the Legislature of the State.
(underlining is ours)

20. In Mohinder Singh Gill v. Chief Election Commissioner , another Constitution Bench considered the ambit of the bar contained in Article 329(b) of the Constitution. Speaking for himself, M.H. Beg, Chief Justice and P.N. Bhagwati, J, Justice V.R. Krishna Iyer held:

The plenary bar of Article 329(b) rests on two principles; (1) The peremptory urgency of prompt engineering of the whole election process without intermediate interruptions by way of legal proceedings challenging the steps and stages in between the commencement and the conclusion. (2) The provision of a special jurisdiction which can be invoked by an aggrieved party at the end of the election excludes other form, the right and remedy being creatures of statutes and controlled by the Constitution. Durga Shanker Mehta, 1955 (1) SCR 267 : AIR 1954 SC 520, has affirmed this position and supplemented it by holding that, once the Election Tribunal has decided, the prohibition is extinguished and the Supreme Court's overall power to interfere under Article 136 springs into action. In Hari Vishnu, 1955-1 SCR 1104 : AIR 1955 SC 233, this Court upheld the rule in Ponnuswami AIR 1952 SC 64, excluding any proceedings, including one under Article 226, during the on-going process of election, understood in the comprehensive sense of notification down to declaration. Beyond the declaration comes the election petition, but beyond the decision of the Tribunal the ban of Article 329(b) does not bind.
(underlining is ours)

26. In Boddula Krishnaiah v. State Election Commissioner , the Supreme Court considered various interlocutory orders passed by this Court, during the ongoing process of election relating to a Gram Panchayat in Nalgonda District and held:

Thus, there is a constitutional bar on interference with the election process except by an election petition presented to an Election Tribunal constituted under the law enacted by the competent Legislature.

27. The Supreme Court then referred to the judgments of N.P. Ponnuswami v. Returning Officer, Nammakkal Constituency (supra), Lakshmi Charan Sen v. A.K.M. Hassan Uzzaman , State of U.P. v. Pradhan Sangh Kshetra Samiti (supra) and observed:

Thus, it would be clear that once an election process has been set in motion, though the High Court may entertain or may have already entertained a writ petition, it would not be justified in interfering with the election process giving direction to the Election Officer to stall the proceedings or to conduct the election process afresh, in particular when election has already been held in which the voters were allegedly prevented to exercise their franchise. As seen, that dispute is covered by an election dispute and remedy is thus available at law for redressal.