Judicial discipline in customs confiscation requires follow-through on prior coordinate findings about personal jewellery and absence of mala fide.

Confiscation of jewellery and currency under the Customs Act was challenged on the basis that a prior two-member Tribunal had already found no mala fide, treated the jewellery as personal jewellery, and recognised TRA facilities. The Tribunal applied judicial discipline and held that the single-member Bench should have followed the earlier coordinate finding. On that footing, the impugned order was set aside and the appeal was allowed with consequential relief according to law.

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Issues: Whether the confiscation of the appellant's jewellery and currencies under Section 111 of the Customs Act, 1962 could be sustained when a prior two-member Tribunal order had found no mala fide and treated the jewellery as personal jewellery covered by TRA facilities.

Analysis: The Tribunal noted that a two-member Bench had already considered the matter and recorded a finding that no mala fide could be attributed to the appellant, the jewellery was personal jewellery, and TRA facilities were available. In these circumstances, judicial discipline required the single-member Bench to follow that finding.

Conclusion: The impugned order was set aside and the appeal was allowed with consequential relief according to law.

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