Refuses Fahim Ahmad's Petition Over Disputed Waiver of
The has dismissed a filed by Fahim Ahmad challenging the absolute of a gold bar by , holding that the matter involves that are more appropriately examined by the .
A Division Bench of Justice Anil Kshetarpal and Justice Shail Jain observed that while the existence of an does not completely bar the High Court's , the present case required examination of factual circumstances surrounding the alleged waiver of a and .
Case Background
Fahim Ahmad arrived at the Indira Gandhi International Airport in New Delhi from Bahrain on . After crossing the Green Channel, intercepted him and recovered a gold bar weighing 116 grams, engraved with "NAIF" and bearing 999 purity. The gold was detained and subsequently absolutely confiscated by the adjudicating authority, which also imposed a penalty of ₹1.15 lakh on Ahmad under .
The recorded a statement from Ahmad under Section 108 of the Act on the same day. According to the Department, Ahmad stated that he did not require issuance of a or a . The Department further relied on a communication dated , submitted through Ahmad's authorized representative, reiterating the same position. The authorities contended that an had been issued in terms of the first proviso to Section 124 of the Act.
Ahmad challenged the before the , who dismissed the appeal on . He then approached the High Court by way of the present .
Arguments Presented
Ahmad's counsel argued that no written under Section 124 of the Customs Act had been issued before the order, and that the requirement of a is mandatory and cannot be dispensed with. It was submitted that the document dated , relied upon by the Department, was not a valid statement under Section 108 and that Ahmad had been made to sign it without its contents being explained. The petitioner also disputed that the recital regarding not requiring a could amount to a valid request for an oral notice.
On the other hand, the Department submitted that the statement was voluntary and never retracted, and that an had been issued. It further argued that the petitioner had an efficacious by way of under Section 129DD of the Act.
Legal Analysis
The Court noted that the controversy could not be resolved merely by noticing that no written was issued. The first proviso to Section 124 contemplates an oral notice at the request of the person concerned. Therefore, the precise question required examination of the documents and circumstances surrounding the alleged statement, the request concerning the , and the oral notice.
The Court observed that the petitioner disputed the character, voluntariness, and legal effect of the documents relied upon by the Department.
"These competing assertions assume significance because the relief sought by the Petitioner would require this Court, in exercise of its
, to examine the factual circumstances in which the documents were executed and to determine the effect thereof,"
the Court said.
The Court further noted that the Customs Act provides a specific revisionary remedy against the under Section 129DD, which is the appropriate forum for examining disputed factual and legal issues.
Key Observations
The Court made the following key observations:
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"This Court is of the view that these disputed questions ought not to be conclusively adjudicated in the present proceedings under Article 226 of , particularly when the statute provides a specific revisionary remedy against the ."
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"The present case is distinguishable from a case where the relevant facts are admitted and the controversy is confined to a ."
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"The Respondent, during the course of hearing, has fairly stated that the Department is willing to afford the Petitioner an opportunity of and to reconsider the matter in accordance with law within a time-bound period. This statement is taken on record."
Court's Decision
The High Court dismissed the petition with liberty to Ahmad to avail the statutory remedy of under Section 129DD of the Customs Act against the dated . The Court directed that if the petitioner avails the remedy within four weeks, the revisional authority shall not reject it on the ground that he had approached the High Court.
The Court clarified that the dismissal should not be construed as an expression of opinion on the merits, and all questions, including the validity of the statement dated , the alleged , and the legality of the and penalty, are left open for the competent authority to consider in accordance with law.