Natural justice required before security forfeiture; non-compliance with hearing safeguards led to remand for fresh adjudication.

Forfeiture of security under Regulation 20 of the Customs House Agents Licensing Regulations, 2004 could not be sustained without compliance with Regulation 22's procedural safeguards, including a fair opportunity of hearing. The absence of natural justice and denial of hearing rendered the forfeiture order unsustainable. The impugned order was set aside and the matter remitted for fresh adjudication in accordance with law after granting due opportunity to the appellant.

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Issues: Whether an order for forfeiture of security under Regulation 20 of the Customs House Agents Licensing Regulations, 2004 could be sustained without following the procedure and safeguards under Regulation 22, including fair opportunity of hearing.

Analysis: Regulation 20 was treated as subject to the mandatory requirements of Regulation 22. The absence of compliance with the rule of natural justice and denial of fair opportunity rendered the forfeiture order unsustainable.

Conclusion: The impugned order was set aside and the matter was remitted to the Commissioner to proceed afresh in accordance with law after granting due opportunity of hearing to the appellant.

Final Conclusion: The appellant succeeded on the procedural fairness issue, and the matter was sent back for fresh adjudication.

Ratio Decidendi: Where a statutory provision incorporates or is controlled by procedural safeguards requiring fair hearing, non-compliance with those safeguards vitiates the resulting order and warrants remand for fresh decision-making.

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