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G.Gopalakrishnan vs The Deputy Director

In fact, in the decision of the Delhi High Court in "J.Sekar versus Union of India & others, etc." (cited supra) relied upon by both learned Senior Counsel for the petitioners and learned Addl.Solicitor General for respondents, it was held that less than three Member Adjudicating Authority is permissible under PMLA. The Delhi High Court held that there can be a single Member of Adjudicating Authority and appellate Tribunal under PMLA and such single Member Bench need not mandatorily have judicial members and can be administrative members as well. This case was relied upon by the learned Addl.Solicitor General for the purpose of contending that the issue of coram non-judice is not a valid argument in the teeth of various provisions which explicitly provide for formation of single Member Bench. This Court is in agreement with the submission made by the learned Addl.Solicitor http://www.judis.nic.in 187 General that it is not mandatory to have three Member Bench all the time for all adjudication purposes. It is up to the Chairperson of the Adjudicating Authority to form Bench containing one or two Members as it deems fit in order to adjudicate the cases which are placed for consideration before the Authority.
Madras High Court Cites 175 - Cited by 0 - V Parthiban - Full Document

Ms Krrish Realtech Pvt Ltd Through Its ... vs Union Of India Through Seceratary ... on 3 November, 2025

xvi. Lastly it is averred that the petitioners' contention that the Adjudicating Authority was not properly constituted is untenable. As per Section 6(5)(b) read with Section 6(13) of the PMLA, a bench of the learned Adjudicating Authority can be constituted with a single member as well. Reliance has been placed on Gold Croft Properties Pvt. Ltd. v. Directorate of Enforcement, 2023 SCC OnLine Del 1154; J. Sekar v. Union of India, 2018 SCC OnLine Del 6523; Alaknanda Realtors Pvt. Ltd. v. Directorate of Enforcement, W.P.(C) 12243/2022; Dyani Anthony Paul v. Union of India, 2020 SCC OnLine Kar 4995; and G. Gopalakrishnan v. Deputy Director, ED, W.P.(MD) No. 11454/2018, (Madras High Court Judgment).
Delhi High Court Cites 57 - Cited by 0 - S Datta - Full Document

Kp Sanghvi And Sons Llp & Anr. vs Directorate Of Enforcement on 27 October, 2021

65. Both parties have made detailed submissions on the question whether the 'reasons to believe' recorded by the Director ED, or the person authorized, at the time of search and seizure have to be provided to the parties concerned or not. On behalf of the Petitioners, the judgment in J. Sekar vs. Union of India 246 (2018) DLT 610 is relied on to argue that the 'reason to believe' recorded by the Director ED, or the person authorised under Section 5(1) has to be given to the party concerned, and therefore similarly 'reasons to believe' recorded by the person authorised under Section 17(1A) also have to be given to the parties concerned. The Respondent, however, has argued to the contrary stating that 'reasons to believe' under Section 17(1A) are not to be provided to the party concerned.
Delhi High Court Cites 63 - Cited by 1 - P M Singh - Full Document

Ajeet Pandey vs Directorate Of Enforcement on 13 February, 2024

(22) It has been submitted on the basis of such judgment that not only the Division Bench in Gold Croft Properties (supra) but also a Division Bench of the Delhi High Court in bunch of the writ petitions leading case of which was J. Sekar vs. Union of India & Ors. in Writ Petition No.5320 of 2017 by its judgment and order dated 11.01.2018 had rejected the arguments of the writ petitioners therein regarding defective composition of the Adjudicating Authority.
Allahabad High Court Cites 27 - Cited by 0 - S Chandra - Full Document
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