Single-Member tribunal jurisdiction depends on case complexity; substantial legal or constitutional issues should go to a two-Member Bench.

Section 5(2) of the Administrative Tribunals Act, 1985 contemplates the ordinary hearing of matters by a two-Member Bench, but Section 5(6) creates a limited exception permitting a Chairman or authorised Member to sit singly for classes of cases specified by general or special order. The provisions were read harmoniously to preserve the legislative scheme and litigants' interests. Matters involving complex questions of law or constitutional interpretation should ordinarily go before a two-Member Bench, while simpler cases may be assigned to a single Member. The proviso to Section 5(6) also permits transfer to a two-Member Bench where the nature of the case so requires.

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Issues: Whether a single Member of the Central Administrative Tribunal could exercise jurisdiction under Section 5(6) of the Administrative Tribunals Act, 1985, and the manner in which Section 5(2) and Section 5(6) were to be construed.

Analysis: Section 5(2) contemplates the ordinary composition of a Bench of two Members, but Section 5(6) creates an exception enabling the Chairman or an authorised Member to function as a single-Member Bench for classes of cases specified by general or special order. The provisions were construed harmoniously, with regard to the legislative scheme and the need to protect litigants' interests. Cases involving complex questions of law or interpretation of constitutional provisions should not ordinarily be assigned to a single Member, while simpler matters may be so allocated. The proviso to Section 5(6) also enables transfer to a Bench of two Members where the nature of the case so requires, and a request by a party for such transfer should ordinarily be allowed.

Conclusion: A single Member is competent to hear matters under Section 5(6) of the Administrative Tribunals Act, 1985, subject to the nature of the litigation and the requirement that cases involving substantial legal or constitutional questions be placed before a two-Member Bench.

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