Statutory appellate remedy under PMLA bars writ review where factual disputes and limitation questions are better left to the Tribunal.

A writ challenge to a PMLA confirmation order was held inappropriate where a statutory appeal lay to the Appellate Tribunal and the dispute involved contested facts on notice and the petitioner's knowledge; the court declined writ intervention and directed the petitioner to pursue the appellate remedy. On the objection that the confirmation order was passed after the prescribed 180-day period, the court held that authorities on Article 21 and Section 167(2) CrPC did not extend to property-rights proceedings under Article 300-A, and it left the limitation issue open for the Tribunal. The writ petition was therefore not entertained on merits.

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Issues: (i) Whether the writ petition was maintainable in view of the statutory appellate remedy under the Prevention of Money Laundering Act, 2002; (ii) Whether the confirmation order under the Prevention of Money Laundering Act, 2002 was without jurisdiction for having been passed after the prescribed period of 180 days.

Issue (i): Whether the writ petition was maintainable in view of the statutory appellate remedy under the Prevention of Money Laundering Act, 2002.

Analysis: The impugned confirmation order was amenable to appeal before the Appellate Tribunal under the statutory scheme. The challenge involved disputed factual assertions regarding notice to the company and the petitioner's knowledge, which were not suitable for adjudication in writ proceedings. The availability of the alternative remedy weighed against entertaining the writ petition.

Conclusion: The challenge to maintainability was rejected and the petitioner was left to pursue the appellate remedy.

Issue (ii): Whether the confirmation order under the Prevention of Money Laundering Act, 2002 was without jurisdiction for having been passed after the prescribed period of 180 days.

Analysis: The Court held that the reliance placed on decisions concerning personal liberty under Article 21 and Section 167(2) of the Code of Criminal Procedure, 1973 could not be extended to proceedings involving property rights under Article 300-A of the Constitution of India. It also noted that the limitation issue was being kept open so that it could be agitated before the Appellate Tribunal, and declined to decide the jurisdictional objection in writ proceedings.

Conclusion: The jurisdictional objection was not accepted in writ jurisdiction and was left open for consideration before the Appellate Tribunal.

Final Conclusion: The writ petition was not entertained on merits and the petitioner was directed to work out the statutory appellate remedy.

Ratio Decidendi: Where a statutory appellate remedy is available and the dispute raises factual and jurisdictional questions better suited for that forum, writ jurisdiction need not be exercised, especially when the issue is left open for determination by the appellate authority.

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