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54. Finally, in Gujarat Urja Vikas Ltd. vs. Essar Power Ltd.19, while examining the composition and working of Tribunals and statutory framework thereof, this Court reiterated its earlier decisions in L. Chandra Kumar (supra) and Madras Bar Association (2014) (supra), observing that remedy of appeal to this Court was in effect, being obliterated due to cost and inaccessibility. In addition to this, a flood of appeals from all the Tribunals directly to this Court hindered its efficiency in fulfilling its primary Constitutional role. Since appellate tribunals, manned by non- judicial members, were adjudging complex questions of law, the composition of Tribunals was put under review by this Court and a reference to the Law Commission of India was made in this regard. Pursuant to this, the Law Commission of India, in its 272nd Report titled ‘Assessment of Statutory 18 (2015) 8 SCC 583.