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In *L. Chandrakumar v. Union of India*, AIR 1997 SC 1125, the **seven-judge bench** of the Supreme Court held that:
A{'text': 'Parliament has no power to set up tribunals to replace the High Courts for any matter under any law in force in India regardless of the field of the legislation under any provision of the Indian Constitution', 'label': 'A'}
B{'text': 'The power of judicial review of the High Court under Article 226 of the Constitution cannot be eliminated by the Parliament', 'label': 'B'}
C{'text': 'Tribunals once constituted oust the jurisdiction of the High Courts under Article 226 in respect of every matter under any law in force in India regardless of the field of the legislation in question', 'label': 'C'}
D{'text': 'Tribunals once constituted oust the jurisdiction of the Supreme Court under Article 32 in respect of every matter under any law in force in India regardless of the field of the legislation in question', 'label': 'D'}
Answer & Solution
Correct answer: B. {'text': 'The power of judicial review of the High Court under Article 226 of the Constitution cannot be eliminated by the Parliament', 'label': 'B'}
1. *L. Chandrakumar v. Union of India*, AIR 1997 SC 1125, is the leading authority on tribunals' relationship with the constitutional courts.
2. The seven-judge bench held that the power of **judicial review of the High Court under Article 226** of the Constitution **cannot be eliminated by Parliament** — Articles 32 and 226 form the basic structure.
3. Tribunals may continue to act like courts of first instance in their fields.
4. The other options misstate the holding.
_Source: ICSI CS Executive Paper 1 — Jurisprudence, Interpretation & General Laws, Lesson 12 (Special Courts, Tribunal under Companies Act and other Legislations), pp. 273-283._
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