JUDGMENT :

S. Muralidhar, J.

1. The Great Eastern Shipping Company Limited (Petitioner No.1) and its Company Secretary (Petitioner No.2) have filed this writ petition seeking three reliefs. First, for a declaration that condition No.82 of Sl. No.462 of Notification No.12/2012 Cus. dated 17th March, 2012 issued by the Department of Revenue, Ministry of Finance, Government of India to the extent it has made the import of the vessel ‘Jag Arnav’, retrospectively amenable to customs duty is ultra vires under Sections 12, 25 and 46 of the Customs Act, 1962 (‘Act’) and Articles 14, 19 (1) (g), 265 and 300A of the Constitution of India. The second prayer is for a direction to the Assistant Commissioner, Central Excise, Customs & Service Tax, Balasore Division, Orissa (Opposite Party No.3) and the Commissioner, Central Excise, Customs & Service Tax, Bhubaneswar-1 (Opposite Party No.4) not to deny Petitioner No.1 permission to convert the vessel ‘Jag Arnav’ to ‘coastal status’ and not to charge customs duty. The third is to prohibit Opposite Party No.3 from withholding permission to convert the