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27. A Full Bench of the Punjab High Court in Sultan Ali Nanghiana v. Nur Hussain, AIR 1949 Lah 131, examined the question whether the Election Commissioners are Courts subordinate to the High Court within the meaning of Section 115, C.P.C. and Section 44, Punjab Courts Act, and referring to Section 3, C.P.C. held that it cannot be taken to mean that the Courts established under any other enactment for the time being in force are all subordinate to the High Court. The broad and unqualified proposition that once it is held that an officer, authority or functionary is exercising the functions of a Court in relation to rights that may be called 'Civil' that officer, authority or functionary must be held to be subordinate to the High Court was rejected. The result of any such finding would be that all Courts which adjudicated upon the civil rights of subjects whether in cases between the subject themselves or between the State and the subject will be subordinate to the High Court and this will bring within the sphere of subordination not only the revenue Courts which admittedly decide civil disputes between the parties but also the income-tax authorities which determine the subject's liability to the State. One clear indication of subordination has always been held to be that the Court whose subordination is in question is subject to the appellate jurisdiction of the High Court. A Court may also be subordinate to the High Court even qua matters which are not subject to the High Court's appellate power if these matters had been entrusted for adjudication to an admittedly subordinate Court as a Court and not to the presiding officer of such Court as a persona designata. Their Lordships divided the cases into three categories: (1) those in which the special Court was held to be subordinate to the High Court because a limited right of appeal to the High Court existed from the decision of that Court; (2) where a Court, whose subordination to the High Court could not be doubted, was given some additional jurisdiction; and (3) those in which the High Court interfered with the decisions of the inferior Court under Section 107 of the Government of India Act, 1915. The existence of a right of appeal from the decisions of a Court to a superior Court is a well-recognised test of subordination even qua cases in which no appeal lies and a Court may be held to be subordinate to another Court in cases in which there is no right of appeal to that Court. The other well-recognised rule is that where the jurisdiction of a Court is enlarged by entrusting for adjudication to it and not to its Presiding Officer as a persona designata certain new matters, the incident of the subordination of that Court to the superior Court remained unaffected even in respect of such new matters. The third category of cases are now obsolete in view of the amended Section 224, Government of India Act, which has been substituted for Section 107, Government of India Act, 1915 and which expressly provides that the administrative functions of the High Court are the same as the power of superintendence under the replaced section shall not be construed as giving to the High Court any jurisdiction to question any judgment of any inferior Court which is not otherwise subject to appeal or revision. On the above analysis, it was held that the Election Petitions Commissioners are not a Court subordinate to the High Court and are an independent and special Tribunal exercising exclusive jurisdiction in a defined class of cases.