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N.P. Ponnuswami vs Returning Officer, ... on 21 January, 1952

"19. It is well-settled principle that where elections are conducted in accordance with the provisions of a statute and the statute also provides a remedy of settlement of election disputes by filing an election petition before a tribunal, it is that remedy alone which should be availed of and recourse cannot be taken to proceedings under Article 226 of the Constitution. This view has been taken in series of decisions rendered by this Court. The earliest decision was rendered in N.P. Ponnuswami vs. The Returning Officer AIR 1952 SC 64 by a Bench of six learned Judges. In this case the nomination paper of the appellant for election to Madras Legislative Assembly was rejected by the Returning Officer. The appellant challenged the rejection of the nomination paper by filing a writ petition in the High Court which was dismissed on the ground that it had no jurisdi1ction to interfere with the order of the Returning Officer on account of Article 329(b) of the Constitution, which says that no election to either House of Parliament or 7 to the House or either House of the Legislature of a State shall be called in question except by an election petition presented to such authority and in such manner as may be provided for by or under any law made by the appropriate Legislature. In appeal, this Court examined the question whether the writ petition would be maintainable at the initial state against an order rejecting the nomination paper. Certain observations made in para 9 of the reports are relevant and they are being reproduced below:
Supreme Court of India Cites 27 - Cited by 605 - S S Ali - Full Document

K.K. Shrivastava And Ors. vs Bhupendra Kumar Jain And Ors. on 15 March, 1977

In K.K. Shrivastava vs. Bhupendra Kumar Jain AIR 1978 SC 1703, the dispute related to election to Bar Council of Madhya Pradesh under the Indian Advocates Act and Rule 31 of Election Rules framed by Bar Council of Madhya Pradesh provided that all disputes arising under the Rule shall be decided by a tribunal to be known as an election tribunal. The defeated candidate approached the High Court under Article 226 of the Constitution challenging the validity of the election which was allowed by the High Court. This Court set aside the judgment of the High Court with the following observations:[SCC p. 496, para 3] "Where there is an appropriate or equally efficacious remedy the Court should keep its hands off. This is more particularly so where the dispute relates to an election. Still more so where there is a statutorily prescribed remedy which almost reads in mandatory terms."
Supreme Court of India Cites 2 - Cited by 63 - V R Iyer - Full Document
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