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2025 Supreme(Online)(Del) 45209

IN THE HIGH COURT OF DELHI AT NEW DELHI
Sachin Datta, J
Syndicate Innovations International Ltd – Appellant
Versus
Directorate General Of Foreign Trade – Respondent
W.P.(C) 6834/2025 | W.P.(C) 7408/2025 | W.P.(C) 7411/2025



Advocates:
For the Appellants/Petitioners: Kanak Bose, Joy Basu, Anoop George
For the Respondents: Premtosh K. Mishra, Siddharth Bajaj, Praraboh Tiwari

Administrative authorities must pass reasoned orders that account for all material facts, including previous litigation outcomes and regulatory uncertainties. Inconsistency in granting relaxations to similarly situated entities constitutes arbitrariness, and decisions must be transparent, comprehensive, and based on objective justifications rather than cryptic observations.

Headnote:(A) Administrative Law - Duty to provide reasoned orders - Rejection of request for extension of commercial import authorization without considering relevant history of litigation and administrative uncertainty renders the decision unsustainable. (Paras 16, 17, 21)

(B) Administrative Actions - Principle of consistency - Where an authority has granted relaxation to similarly situated applicants facing analogous constraints, a deviation in the present case without clearly stated justification is arbitrary. (Para 18)

Facts of the case:
The petitioner held import authorizations that remained unutilized due to inter-ministerial confusion and subsequent legal proceedings, which were ultimately decided in the petitioner's favor. Applications for revalidation of these authorizations were rejected by an administrative committee, which cited a lack of justification for claimed hardships.

Findings of Court:
The court observed that the rejection order was cryptic and failed to account for pertinent circumstances, including the successful conclusion of litigation and prevailing regulatory uncertainty. It further noted that the decision lacked consistency when compared to similar cases where relief had been granted.

Issues: Whether the administrative body's decision to reject the revalidation of import authorizations was reasoned, consistent with prior practice, and compliant with principles of fairness.

Ratio Decidendi: Administrative actions must be based on a comprehensive consideration of all relevant facts and must maintain consistency in treatment across similarly situated entities to avoid the vice of an arbitrary exercise of power.

Result: Petitions disposed of with a direction to the committee to re-examine the request and pass a reasoned, transparent order.

Table of Content
1. factual background regarding expired import licenses and failed revalidation applications. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10 , 11 , 12 , 15)
2. allegations of administrative arbitrariness and inconsistent treatment compared to other importers. (Para 13 , 14 , 18 , 19)
3. requirement for administrative authorities to provide reasoned orders when considering revalidation. (Para 16 , 17 , 20 , 21)
4. court mandate to reconsider revalidation application within a structured timeframe. (Para 22 , 23 , 24 , 25)

SACHIN DATTA, J. (Oral)

1. The present petitions have been filed by the petitioners assailing the rejection/inaction on part of the respondent/ Directorate General of Foreign Trade (‘DGFT’) as regards the applications submitted by the petitioners seeking revalidation of import licenses/ authorizations issued by the respondent authority.

2. In W.P(C) 6834/2025, the subject matter pertains to the Import License dated 05.03.2021, bearing Application No.051924189, issued by the DGFT to the petitioner for the import of ‘telescopic sights’ for air weapons. The said license was originally valid for a period of 18 months and was subsequently revalidated by the DGFT on 23.03.2023, with retrospective effect from 04.09.2022 to 04.03.2023.

3. In W.P(C) 7408/2025, the subject matter concerns Import Authorization No. 0519252466 dated 27.01.2021, issued by the DGFT to the petitioner for the import of parts of air weapons. The said authorization, originally valid for 18 months, was granted first revalidation by the respondent on 19.05.2022, thereby extending its validity until 26.01.2023.

4. In W.P(C) 7411/2025, the subject matter pertains to two Import Authorizations, issued by the DGFT to the petitioner:

(i) Import Authorization No. 0519244138 dated 23.10.2020 issued for import of parts of handguns and air weapons, originally valid for a period of 18 months and revalidated until 22.10.2022; and

(ii) Import Authorization no. 0519244145 dated 23.10.2020 issued for import of parts originally valid for a period of 18months and revalidated until 22.10.2022.

5. At the outset, the controversy involved in all these matters is identical. Accordingly, for the sake of convenience and with the consent of learned counsel for the parties, W.P.(C) 7411/2025 is taken as the lead matter for reference to the factual conspectus and relevant documents.

6. The petitioner W.P.(C) 7411/2025 is stated to be an established manufacturer, importer and exporter of air weapons. It is submitted that the petitioner holds valid licenses under the Arms Act,1959 and Arms Rules, issued by the competent authorities (such as the Ministry of Home Affairs for the manufacture of firearms and ammunition and the State Government of Uttar Pradesh for the manufacture of air weapons), authorising the petitioner to undertake such operations.

7. It is averred that the petitioner is the largest supplier of air weapons to the Government of India and is also a government recognized export house of air weapons. The petitioner is stated to have acquired a prominent position in the relevant industry.

8. The present petition arises in the backdrop of the rejection by the DGFT of the petitioner’s applications seeking revalidation of the Import Licenses dated 23.10.2020, bearing Nos. 0519244138 and 0519244145, originally valid for a period of 18 months and were revalidated until 21.10.2022.

9. The factual matrix put forth by the petitioner is that around June 2022, the petitioner, under Import License/Authorization No. 0519244138, imported certain components of firearms. The said consignments were withheld by the Customs authorities on alleged requirement of a separate license. These detentions formed the subject matter of W.P.(C) 10143/2022, which was decided in favour of the petitioner vide judgment dated 07.10.2022. Thereafter, an LPA bearing No.695/2022 filed by the respondent against the said judgment, came to be dismissed on 29.08.2024. Pursuant thereto, SLP (C) N

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