PMLA adjudication through single-member benches is valid; writ relief was refused due to an effective statutory remedy.

Section 6 of the PMLA was construed to permit the adjudicating authority to function through benches, including a single-member bench, and its proceedings were not invalid merely because the member was not a judicial officer. On that reading, the show-cause notice was not liable to be quashed on the ground of coram non judice or improper composition. The writ petition was also not maintainable because the PMLA provides a complete statutory mechanism, including adjudication and appeal to the Appellate Tribunal, and no exceptional ground justified bypassing that remedy. The notice was therefore left undisturbed and the writ challenge failed.

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Issues: (i) Whether the show-cause notice issued under the PMLA was liable to be quashed on the ground that the adjudicating authority acted coram non judice and that the notice was issued by a non-judicial member or a single-member bench; (ii) Whether the writ petition was maintainable in view of the availability of an alternative statutory remedy under the PMLA.

Issue (i): Whether the show-cause notice issued under the PMLA was liable to be quashed on the ground that the adjudicating authority acted coram non judice and that the notice was issued by a non-judicial member or a single-member bench?

Analysis: Section 6 of the PMLA was read as a whole. The composition provision in sub-section (2) does not exclude functioning through benches, because sub-sections (5), (6), (7), (13) and (14) expressly permit constitution of benches with one or two members, transfer between benches, and discharge of the Chairperson's functions by the senior-most member when required. On that construction, a proceeding is not vitiated merely because it is taken up by a single member or by a member who is not a judicial officer. The earlier decisions relied on by the Court supported the view that the statutory scheme permits single-member functioning and that the adjudicating authority is not rendered without jurisdiction for that reason.

Conclusion: The challenge based on coram non judice and improper composition of the adjudicating authority was rejected.

Issue (ii): Whether the writ petition was maintainable in view of the availability of an alternative statutory remedy under the PMLA?

Analysis: The PMLA provides an internal adjudicatory and appellate framework, including adjudication under Section 8 and further statutory challenge before the Appellate Tribunal under Section 26. The writ jurisdiction under Article 226 is ordinarily not to be invoked where an effective remedy exists, especially where the statute creates a complete mechanism for redress. No exceptional ground warranting bypass of that mechanism was found.

Conclusion: The writ petition was held to be not entertainable in view of the available alternative statutory remedy.

Final Conclusion: The impugned show-cause notice was not quashed, and the writ petition failed on both the jurisdictional challenge and the maintainability objection.

Ratio Decidendi: Under Section 6 of the PMLA, the adjudicating authority may validly function through benches, including a single-member bench, and writ interference is ordinarily barred where the statute provides an effective appellate remedy.

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