Statutory tribunal jurisdiction limits single-member disposal; licence dispute had to go before a two-member Bench.

Section 81B of the Gold (Control) Act, 1968 authorises disposal by a single Member of the Appellate Tribunal only where the value of confiscated goods or the fine or penalty involved is within the prescribed limit. The dispute concerned entitlement to a gold dealer's licence, which did not fall within that limited statutory class. Because jurisdiction is statutory, a decision made without the required jurisdiction has no legal effect. The matter therefore had to be heard by a duly constituted two-member Bench, and the single Member could not validly dispose of the appeal.

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Issues: Whether the appeal could be heard and disposed of by a single Member of the Appellate Tribunal under Section 81B of the Gold (Control) Act, 1968.

Analysis: Section 81B permits disposal by a single Member only in cases where the value of the confiscated goods, or the amount of fine or penalty involved, does not exceed the prescribed limit. The matter before the Tribunal concerned the appellant's entitlement to a gold dealer's licence and did not fall within the class of cases covered by that provision. As jurisdiction flows from statute, an order made without the requisite jurisdiction would be without legal effect. The matter therefore required consideration by a duly constituted two-member Bench.

Conclusion: The single Member had no jurisdiction to decide the appeal; the case was transferred to a two-member Bench.

Ratio Decidendi: A single Member of the Appellate Tribunal can act only within the limited statutory jurisdiction conferred by the governing provision, and any disposal beyond that jurisdiction is a nullity.

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