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Issues: Whether the conviction under Section 135 of the Customs Act could be sustained on the basis of the testimony of official witnesses despite non-examination of independent witnesses.
Analysis: The recovery of currency and gold biscuits was consistently proved by the customs and intelligence who participated in the raid, and their evidence was corroborated by the documentary record. The mere fact that independent witnesses were joined but not examined did not render the prosecution evidence unreliable. There is no legal rule that testimony of public officers must be discarded unless supported by independent witnesses; such evidence requires careful scrutiny, not automatic rejection. In the absence of material suggesting enmity, false implication, or any reason to doubt the raid and recovery, the Court found the official witnesses trustworthy. The statement recorded under Section 108 of the Customs Act and the explanation given by the petitioner also formed part of the evidentiary chain.
Conclusion: The conviction and sentence under Section 135 of the Customs Act were upheld and the revision was dismissed.
Ratio Decidendi: Conviction may be sustained on the credible testimony of official witnesses even if independent witnesses are not examined, where the evidence is reliable and proves guilt beyond reasonable doubt.