( 1 ) THE Customs Authorities and the Union of India have filed an appeal against two interlocutory orders dated June 21, 1982 and July 12, 1982 passed by a learned Single Judge of this Court. The said two interlocutory orders have been passed by the learned Judge in the Rule Nisi issued on the writ petition of Ramniwas Choudhury, carrying on business under the trade name of Choudhury Shipbreaking Co. By the first order, the learned Judge restrained the Central Government from proceeding with a revision case suo moto started by it against the petitioner under Section 131 (3) of the Customs Act, 1962 and, by the second order, the learned Judge directed the Customs Authorities to refund to the petitioner a sum of Rs. 35,98,428/- plus Rs. 2,91,000/- upon furnishing a bank guarantee for the aggregate of the said amounts. It may be stated at the outset that the said sum of Rs. 2,91,000/- is included within the said sum of Rs. 35,98,428/- which has been admittedly paid by the petitioner on account of customs duty for a vessel, and the petitioner claimed a refund of the said sum contending inter alia that no customs duty was payable. The direction of the learned Jud