Tribunal structure and judicial review face renewed scrutiny amid doubts over constitutional validity powers and Bench composition.

The tribunal scheme under Part XIV-A of the Constitution and the Administrative Tribunals Act, 1985 is discussed as having been upheld earlier on the basis of an efficacious alternative mechanism for judicial review. The text notes later decisions recognising tribunal power to decide constitutional validity and permitting single-member Benches in specified cases, but also records judicial reservations about treating tribunals as equivalent to High Courts. In view of those post-Sampath Kumar developments, the commentary states that substantial doubts arose about tribunal structure, Bench composition, and the scope of judicial review, warranting reconsideration by a larger Bench.

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Issues: Whether the validity of Section 5(6) of the Administrative Tribunals Act, 1985, and the broader scheme upheld in earlier precedent required reconsideration by a larger Bench in view of the tribunal's power to decide questions touching judicial review and constitutional validity.

Analysis: The Court noted that the tribunal scheme under Part XIV-A of the Constitution and the Administrative Tribunals Act, 1985 had earlier been upheld on the basis that judicial review could be exercised through an efficacious alternative mechanism. It also noted subsequent decisions recognising a tribunal's authority to decide questions of constitutional validity and the statutory provision permitting a single-member Bench in specified cases. At the same time, later authorities had expressed reservations about equating tribunals with High Courts, and the Court considered that the post-Sampath Kumar line of cases raised substantial questions about the extent of tribunal power, the composition of Benches, and the constitutional position of tribunals in relation to High Court judicial review.

Conclusion: The Court concluded that the issues needed reconsideration by a larger Bench.

Final Conclusion: The matter was not decided on the substantive validity of the impugned provision at this stage, but was directed to be placed before the Chief Justice of India for constitution of an appropriate larger Bench.

Ratio Decidendi: Where later decisions raise substantial doubts about the correctness of an earlier Constitution Bench ruling on tribunal structure and judicial review, the matter may be referred for reconsideration by a larger Bench.

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