Reasonable period requirement barred delayed foreign exchange adjudication after unexplained inaction and resulting prejudice to the defence.

Where the statute prescribed no limitation for adjudication, the authority was still bound to act within a reasonable period. Adjudication over alleged foreign exchange contraventions was initiated more than 12 years after the events, with no satisfactory explanation for the delay and no fault attributable to the petitioner. The Court also noted loss of relevant records and resulting prejudice in defending the matter. The delayed proceedings were therefore held unsustainable and were quashed.

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Issues: Whether adjudication proceedings initiated after an unexplained delay of more than 12 years in relation to alleged foreign exchange contraventions were liable to be quashed for being instituted beyond a reasonable period and for causing prejudice to the petitioner.

Analysis: No period of limitation was prescribed for completion of the adjudication proceedings, but the governing principle was that where the statute is silent, the authority must act within a reasonable period. The Court found that the alleged events were of 1980-82, the memorandum was issued in 1991, and the first notice for hearing came only in 2004. No satisfactory explanation was offered for the prolonged inaction, and the delay was not attributable to the petitioner. The Court also took into account the loss of relevant records and the resulting inability to effectively defend the matter after such a long lapse of time.

Conclusion: The delayed adjudication proceedings were held unsustainable and were quashed in favour of the petitioner.

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