Substantial completion under earlier licensing rules protects candidates from later procedural changes and discriminatory denial of certification.

Candidates who had cleared the written examination under the earlier customs house agents licensing regime could not be denied the certificate because the oral examination was postponed until revised regulations came into force. The court treated substantial completion of the selection process under the earlier regime as decisive, and held that the later procedural change could not retrospectively defeat that position. It also noted that similarly placed candidates had already been granted the same relief, so withholding the certificate would amount to discriminatory treatment. On that basis, entitlement to the certificate under Regulation 8 was affirmed and the challenge to the writ court's direction failed.

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Issues: Whether the respondents were entitled to a certificate under Regulation 8 of the Customs House Agents Licensing Regulations, 2004, when they had cleared the written examination under the earlier regime and the oral examination was held after the revised regulations came into force.

Analysis: The respondents had completed the written examination under the earlier regulations, and the later change in the selection process came into effect only because the oral examination was postponed. The material placed before the Court showed that similarly placed candidates were granted the licence certificate under the earlier regime. In these circumstances, the revised regulations could not be applied so as to deny the respondents the benefit of the process they had substantially completed, and differential treatment would amount to discrimination against persons similarly placed.

Conclusion: The respondents were entitled to the certificate under Regulation 8 of the Customs House Agents Licensing Regulations, 2004, and the challenge to the writ court's order failed.

Final Conclusion: The writ appeal was dismissed, and the direction to grant the requested relief to the respondents was left undisturbed.

Ratio Decidendi: Where candidates have substantially completed the examination process under the earlier regulatory regime, a later procedural change brought about by postponement cannot be used to deny them the benefit of that regime, especially when similarly placed candidates have been granted the same relief.

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