Timely licence renewal under customs agent regulations is mandatory; post-expiry applications may be lawfully rejected.

A customs house agents licence renewal could be refused where the renewal application was filed only after the licence had expired. Rule 13(3) of the Customs House Agents Licensing Regulations, 1965 required renewal to be sought before expiry of the initial one-year licence, after which renewal for three years could follow. The fact that renewal had been granted in some cases did not create a binding entitlement where the applicant's own default caused the delay. On that basis, the department was legally entitled to decline renewal of an expired licence, and the refusal was upheld.

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Issues: Whether renewal of a customs house agents licence could be refused when the application for renewal was made after the licence had expired.

Analysis: Rule 13(3) of the Custom House Agents Licensing Regulations, 1965 required an application for renewal of the initial one-year licence to be made before expiry, after which renewal would follow for three years. The record showed that the appellant applied for renewal after expiry of the existing licence. The practice of permitting renewal in some cases did not create a binding rule where the licensee's own default caused the delay. In such circumstances, the department was entitled to decline renewal of an already expired licence.

Conclusion: The refusal to renew the licence was upheld and the issue was answered against the appellant.

Final Conclusion: The appeal failed because a renewal application made after expiry of the licence could validly be rejected under the governing regulations.

Ratio Decidendi: A renewal application for a customs house agents licence must be made within the prescribed time, and where the licensee applies only after expiry, refusal of renewal is legally sustainable.

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