Common adjudication order can be heard together where baggage and related customs issues arise from the same investigation.

Where a common adjudication order covers interconnected issues arising from the same seizure, search and investigation, the Tribunal need not bifurcate the appeals merely because one aspect concerns import of goods as baggage and may attract the first proviso to Section 129A(1) of the Customs Act, 1962. The Commissioner's order dealt with confiscation and related matters together, so the Tribunal could validly dispose of all connected appeals in one proceeding. On that footing, the rectification application challenging the common disposal was not maintainable, and the earlier order stood.

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Issues: Whether the Tribunal committed any error in disposing of all the appeals arising from a common order of the Commissioner, notwithstanding that one of the issues related to importation of goods as baggage and the first proviso to Section 129A(1) of the Customs Act, 1962 was invoked.

Analysis: The order of the Commissioner did not deal exclusively with confiscation of imported baggage. The seizure at the airport led to further investigation, search of residential premises, recovery of goods and their seizure, and the Commissioner passed one common order covering all the matters. On that basis, the matter could not be bifurcated at the Tribunal stage by sending only the baggage issue to the Government of India while retaining the remaining issues for decision by the Tribunal.

Conclusion: The Tribunal had committed no error in disposing of all the appeals against the common order, and the rectification application was not maintainable on that ground.

Final Conclusion: The request to correct the earlier order failed, and the common disposal of the appeals was upheld.

Ratio Decidendi: Where a common adjudication order covers interconnected issues arising from the same seizure and investigation, the Tribunal is not required to bifurcate the matter merely because one aspect may relate to baggage jurisdiction.

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