Reference jurisdiction limited to questions of law; new factual objections cannot be raised at the reference stage.

A reference application was not maintainable because the objections raised concerned factual appreciation, not a referable question of law. The Tribunal's reliance on the vehicle records, chemical analysis, witness statements and R.G. 1 discrepancies was treated as a factual conclusion. Challenges to the Chemical Examiner's report and the alleged omission of R.G. 1 discrepancies could not be introduced at the reference stage because they had not been specifically raised in the appeal grounds or argued before the Tribunal. The reference jurisdiction was confined to questions of law arising from the Tribunal's order, and the application was rejected.

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Issues: Whether any question of law arose from the Tribunal's order so as to warrant a reference to the High Court under the reference provision, particularly on the grounds relating to appreciation of evidence, reliance on the Chemical Examiner's report, and the alleged non-mention of the R.G. 1 discrepancies in the later show cause notice.

Analysis: The matter turned on whether the applicant had raised a referable question of law or only a challenge to factual appreciation. The finding that the goods vehicle record, the chemical analysis, the early statements of witnesses, and the R.G. 1 discrepancies supported the departmental case was held to be a factual conclusion. The attempted objections regarding the Chemical Examiner's report and the R.G. 1 discrepancies were not available for reference because they had not been specifically raised in the appeal grounds or argued before the Tribunal. The scope of a reference application was held to be confined to questions of law arising out of the Tribunal's order and could not be expanded by introducing new points at the reference stage.

Conclusion: No referable question of law arose and the reference application was not maintainable on the issues urged.

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