Judgment

SUBBA RAO J. : These four petitions are filed under Art. 32 of the Constitution for quashing the orders of the Assistant Controller of Imports and Exports, the Collector of Customs and Central Excise, Pondicherry, the Board of Revenue, and the Government of India, and for an appropriate direction requiring the respondents to refund the amount realised from the petitioners.

2. Messrs. Universal Imports Agency and the proprietor of the agency are the petitioners in the first three petitioners and Messrs. Victory Traders and the petitioners in the last one. The Chief Controller of Imports and Exports, Pondicherry, the Collector of Customs and Central Excise, Pondi-cherry, the Central Board of Revenue, and the Government of India are the respondents in all the petitions.

3. Messrs. French India Importing Corporation and Messrs. B. S. & Co. intervened in the Writ Petitions.

4. Pondicherry was a French Possession in India. On October 21, 1954 the Government of India and the Government of France entered into an agreement (hereinafter called the Indo-French Agreement), whereunder there was a de facto transfer of the administration of the French Settlements to the Government of India (