JUDGMENT - (1) This is a petition under Art. 226 of the Constitution challenging the validity of two orders, oen made by the 1st respondent, viz., Additional Collector of Customs and the second made by the Central Board of Revenue in appeal against the order made by the 1st respondent. The relevant facts as appearing from the documents annexed to the petition and the affidavit in reply are as follows:

(2) In 1955 the petitioner received an inquiry from some foreign customer for export and sale from India for coarse white goat-hair or wool. The petitioner had in that connection sent his inaterial which is described as petitioners type 100AA to that foreign customer. The petitioner was in doubt as to whether he could export his goods as wool waste which did not require export licence or only as raw wool which required export licence. In that connection the petitioners representative interviewed the Deputy Marketing Development Officer in Bombay with a sample: but the officer refused to give any opinion intimating to the petitioner that it was not his function to give opinions to the petitioner.

(3) The petitioner thereafter in 1956 shipped 25 bales of his goods outside India in the e

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