Mandatory inquiry timeline under Customs Brokers Licensing Regulations cannot be ignored; delayed revocation proceedings were set aside.

The mandatory 90-day timeline for completing an inquiry under Regulation 20(5) of the Customs Brokers Licensing Regulations, 2013 was treated as binding. Because the inquiry report was completed and submitted beyond that prescribed period, the revocation proceedings were held unsustainable. The non-compliance with the statutory time limit vitiated the revocation process, and the impugned revocation order was set aside.

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Issues: Whether the revocation of the CHA licence could be sustained when the inquiry under Regulation 20(5) of the Customs Brokers Licensing Regulations, 2013 was not completed within the prescribed 90-day period.

Analysis: The prescribed regulatory timeline for completion of the inquiry was treated as binding. The inquiry in the present matter was completed beyond the stipulated period, resulting in delay in preparation and submission of the report. In view of the settled principle that non-compliance with the mandatory time limit under Regulation 20(5) vitiates the revocation proceedings, the impugned revocation could not be sustained.

Conclusion: The challenge succeeded and the revocation order was set aside.

Ratio Decidendi: Non-compliance with the mandatory time limit for completion of inquiry under Regulation 20(5) of the Customs Brokers Licensing Regulations, 2013 renders the revocation proceedings unsustainable.

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