Binding precedent controls customs licensing dispute as contrary High Court relief and amended regulations fall away.

The challenge to the Customs House Agents Licensing (Amendment) Regulations, 2010 was governed by the Court's earlier binding ruling in Sunil Kohli, and once the Revenue ed that position and Circular No. 06/2013 deleted the contrary paragraphs from Circular No. 09/2010-Customs, the High Court's contrary relief could not stand. The dispute also concerned whether candidates who had passed the Regulation 9 examination under the 1984 Regulations were entitled to a licence without clearing additional subjects under the 2004 Regulations. The Supreme Court set aside the High Court's judgment and applied the earlier decision, with the matter disposed of in favour of the Revenue.

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Issues: Whether the Customs House Agents Licensing (Amendment) Regulations, 2010 quashed by the High Court could survive after the Court's earlier ruling in Sunil Kohli on the same question, and whether candidates who had passed the examination under Regulation 9 of the Customs House Agents Licensing Regulations, 1984 were entitled to grant of licence without clearing the additional subjects prescribed under the Customs House Agents Licensing Regulations, 2004.

Analysis: The appeals were stated to be covered by the earlier decision of the Court in Sunil Kohli. The Revenue accepted that view and, in consequence, Circular No. 06/2013 was issued deleting paragraphs 8.1 and 8.2 of Circular No. 09/2010-Customs. In light of that accepted position, the basis on which the High Court had granted relief no longer survived.

Conclusion: The High Court's judgment and order were set aside and the appeals were disposed of in the same terms as the earlier decision, against the assessees and in favour of the Revenue.

Final Conclusion: The challenge to the High Court's quashing of the amended licensing regulations did not succeed, and the earlier Supreme Court ruling governed the result.

Ratio Decidendi: Where the controversy is squarely covered by an earlier binding decision of the Court and the administrative circular is aligned with that decision, the impugned contrary judgment cannot stand.

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