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As per case facts, the respondent-company's claim to retain agricultural land was denied by a Revenue Officer in 1971, vesting the land in the State. This order attained finality after
...the company's judicial challenges were dismissed. Decades later, the company sought an amicable settlement with the State, leading the State Government to direct a review. In 2008, the Revenue Officer reviewed and set aside the 1971 order, allowing the company to retain significant land. The Tribunal quashed this review, but the High Court reversed the Tribunal's decision. The State appealed to the Supreme Court. The question arose whether a Revenue Officer, a quasi-judicial authority, possessed the power to review its own final order under the WBEA Act, 1953, particularly after it attained finality and without new evidence or apparent error. Finally, the Supreme Court held that the Revenue Officer lacked inherent power of review. Such a power must be expressly conferred by statute, which was absent here. The Court found the 2008 review order void and illegal, restoring the 1971 vesting order.
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