Madras Bar Association v Union of India

• The National Company Law Tribunal (NCLT) was established under the Companies Act, 2013
• Its composition included technical members from varied backgrounds
• Madras Bar Association challenged whether technical members could adjudicate complex legal questions
• The question was the constitutional validity of NCLT's composition

1. Whether the composition of NCLT with technical members hearing pure judicial questions is constitutionally valid.

• Tribunals must have judicial members with qualifications comparable to High Court judges for adjudicating questions of law.
• Technical members bring domain expertise but cannot decide pure legal questions without judicial oversight.
• Security of tenure, adequate qualifications, and independence from executive are essential.
• Laid down minimum standards for all tribunals regarding composition and qualifications.

When tribunals exercise judicial functions (particularly deciding questions of law), their composition must include judicial members with appropriate qualifications. This ensures competence and independence comparable to courts whose jurisdiction they exercise.