RATAN LAL ADUKIA & ANR. vs UNION OF INDIA

The Supreme Court held that Section 80 of the Indian Railways Act, 1890, is a complete and self-contained special law regarding the jurisdiction for filing suits for compensation against Railways, thus implying the repeal of conflicting provisions in Section 20 of the Code of Civil Procedure, 1908, and Section 18 of the Presidency Small Cause Courts Act, 1882. The Court dismissed the appeals, affirming that the legislative intent was to establish a clear jurisdictional framework for such suits, which does not allow for simultaneous application of the general provisions. The ruling emphasizes the doctrine of implied repeal in statutory interpretation.