Locus standi to challenge redemption fine requires owner's authority; an employee cannot appeal confiscation in a corporation's name.

An appeal against redemption fine on confiscated property is maintainable only at the instance of the owner or a duly authorised appellant. Where a bus was confiscated under Section 115(2) of the Customs Act and the goods in it were absolutely confiscated under Section 111(d), the right to challenge the redemption fine vested in UPSRTC as owner of the bus. The Regional Manager, being only an employee and not a separate legal entity, had no independent locus standi to contest the order, and no authorisation from UPSRTC was shown. An appeal filed in the Regional Manager's name was therefore not competent.

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Issues: Whether the appeal against redemption fine imposed on confiscation of the bus was maintainable at the instance of the Regional Manager of UPSRTC, who was not shown to be the owner or an authorised appellant.

Analysis: The bus stood confiscated under Section 115(2) of the Customs Act, while the goods found in it were absolutely confiscated under Section 111(d) of the Customs Act. The right to challenge the redemption fine belonged to the owner of the bus, namely UPSRTC. The Regional Manager, as an employee, had no independent locus standi to contest the impugned order, and there was nothing on record to show authorisation by UPSRTC. An appeal filed in the name of the Regional Manager, who is not a separate legal entity, was therefore not competent.

Conclusion: The appeal was not maintainable and was liable to be dismissed.

Ratio Decidendi: An employee or office bearer of a corporation has no independent locus standi to challenge redemption fine imposed on confiscated property unless the owner has authorised the appeal or the appeal is otherwise filed in the owner's name.

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