Review jurisdiction cannot reopen FEMA merits when statutory remedies remain available and no apparent error is shown.

Review jurisdiction cannot be used to reopen the merits of a writ order where the earlier dismissal rested on the availability of statutory remedies under FEMA. The court treated complaints about delay in issuing the show cause notice, reasonable time, the alleged pre-notification nature of the violation, FDI policy, and factual questions on exit from the company or group company status as matters for the adjudicating authority. It also noted that FEMA provides further appellate remedies, including on questions of law, which reinforced the limited scope of review. No error apparent on the face of the record was shown, and the review applications were dismissed.

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Issues: Whether the review applications disclosed any error apparent on the face of the record in the earlier writ order, and whether the petitioners could reopen the merits of the show cause notice notwithstanding the availability of statutory remedies under FEMA.

Analysis: The challenge in review was directed principally against the earlier dismissal of the writ petitions on the ground of alternative remedy. The grounds urged on delay in issuing the show cause notice, the applicability of precedent on reasonable time, the alleged pre-notification nature of the violation, the status of the FDI policy, and factual questions such as exit from the company or the definition of group company were all held to be matters going to the merits, which could be urged before the adjudicating authority. The earlier writ order had already considered the delay issue and had taken the view that reasonableness depended on the facts and circumstances and could be examined in the statutory adjudicatory process. The existence of further remedies under FEMA, including appeal and further appeal on questions of law, reinforced the limited scope of interference in review.

Conclusion: No error apparent on the face of the record was made out. The review applications were not maintainable as a vehicle for re-arguing the merits, and they were dismissed.

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