Reasoned adjudication under the SAFEM Act is required; a cryptic writ order without examining notices and forfeiture orders cannot stand.

A reasoned adjudication is required where the validity of statutory notices and forfeiture orders under the SAFEM Act is challenged. A High Court order that merely followed an earlier decision, without examining the factual matrix, the show cause notices under Section 6, the forfeiture orders under Section 7, or the governing statutory provisions and case law, cannot be sustained. The matter must therefore be reconsidered on the relevant facts and law. The Supreme Court found the cryptic disposal unsustainable and remitted the cases for fresh consideration in accordance with law.

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Issues: Whether the High Court's brief order allowing the writ petitions by reference to an earlier decision, without examining the facts, the notices under Section 6 and the forfeiture orders under Section 7 of the Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976, could be sustained.

Analysis: The High Court did not advert to the factual matrix, the validity of the show cause notices, or the forfeiture orders under the SAFEM Act. It also did not examine the statutory provisions invoked or the decisions of the Court governing the Act. Where a court disposes of matters by a cryptic order merely following another case, without applying the relevant statutory framework and facts, such an order cannot stand and the matter requires reconsideration.

Conclusion: The High Court's order was unsustainable and the matters were required to be remitted for fresh consideration in accordance with law.

Ratio Decidendi: A reasoned adjudication is necessary where the validity of statutory notices and forfeiture orders is in issue, and a brief order disposing of the matter by mere reference to an earlier decision without examining the relevant facts and provisions cannot be sustained.

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