Statutory appellate remedy and writ maintainability limit interim relief for payment system authorisation disputes.

The Payment and Settlement Systems Act, 2007 provides a statutory framework for grant, refusal, revocation and appeal against authorisation to operate a payment system. The text states that where the statute provides a complete appellate remedy, writ jurisdiction should not be used to seek interim continuation of the authorisation instead of pursuing that appeal. It also notes that the petition was treated as unsupported by proper authority from the foreign company holding the authorisation, and that no material part of the cause of action arose within the territorial jurisdiction of the Madurai Bench. On that basis, the writ petition was described as non-maintainable for lack of locus standi, want of territorial jurisdiction and misuse of the writ process.

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Issues: Whether the writ petition was maintainable in view of the pending statutory appeal, absence of territorial cause of action and lack of locus standi, and whether the petitioner could seek continuance of the authorisation through interim writ relief.

Analysis: The Payment and Settlement Systems Act, 2007 creates a statutory framework under which authorisation to operate a payment system is granted, refused, revoked and appealed against before the Central Government. The impugned communication was issued by the Reserve Bank of India on the basis of the applicant's financial status, integrity and the pending criminal proceedings, and the statute itself provided an appeal under Section 9. The petition was found to have been filed without proper authorisation from the foreign company, which was the holder of the authorisation, and the events giving rise to the impugned decision occurred outside the territorial jurisdiction of the Madurai Bench. The Court also held that a writ forum cannot be used to obtain interim continuation of the very relief that should be worked out in the statutory appeal, and that the attempt to secure such relief amounted to abuse of process and forum shopping.

Conclusion: The writ petition was not maintainable and failed on the grounds of absence of locus standi, want of territorial jurisdiction and misuse of writ jurisdiction to bypass the statutory appellate remedy.

Ratio Decidendi: Where a special statute provides a complete appellate mechanism, a writ petition should not be entertained to secure interim continuation of the statutory benefit, particularly when the petitioner lacks proper authority and no material part of the cause of action arises within the court's jurisdiction.

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