The correct answer is (a). Courts of Native Commissioner did not fall under civil Judicature.
The other options are:
(b) Zila Courts: These were district courts that had jurisdiction over civil and criminal cases.
(c) Courts of Circuit: These were courts that traveled from place to place and had jurisdiction over civil and criminal cases.
(d) Sadar Dewani Adalat: This was the highest court in the province of Bengal and had jurisdiction over civil and criminal cases.
Courts of Native Commissioner were established in British India to deal with cases involving native law and custom. They were not part of the civil Judicature, which was the system of courts that dealt with cases under British law.