Customs assessment finality excludes civil suits after statutory appeal and revision under the Sea Customs Act scheme.

The Sea Customs Act, 1878, as applied through the Land Customs Act, 1924, was treated as a self-contained code for customs assessment, appeal, revision and finality. The expression "decision or order" in Section 188 was read broadly to include a determination of the applicable rate of duty, not merely confiscation or penalty orders. Because the statute created the liability and provided its own exclusive remedy, the finality under Section 188, together with revision under Section 191, excluded further civil court challenge. The suit was therefore barred after the statutory appeal and revision had been pursued.

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Issues: Whether, after an appeal under Section 188 of the Sea Customs Act, 1878 and revision under Section 191, the civil courts retained jurisdiction to entertain a suit challenging the customs assessment and levy.

Analysis: The statutory scheme under the Sea Customs Act, 1878, as applied by Section 9 of the Land Customs Act, 1924, provided a self-contained machinery for assessment, appeal, revision and finality. The words "decision or order" in Section 188 were construed broadly enough to include a determination of the rate of duty applicable to the goods, not merely adjudications of confiscation, penalty or increased rate of duty under Section 182. The finality declared by Section 188, read with the revisional power in Section 191, was treated as excluding any further challenge in civil court where the statute created the liability and supplied its own exclusive remedy. The Court also relied on the earlier customs legislation to confirm that the appeal structure was intended to be comprehensive.

Conclusion: The civil court's jurisdiction was excluded, and the suit was barred after the statutory appeal and revision had been pursued.

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