Declarant's continuing liability under Central Excise Rules was not avoided by mere authorisation under Rule 3.

Liability under Rule 221 of the Central Excise Rules, 1944 was treated as an independent statutory obligation attaching to the person who signed the declaration. Mere authorisation under Rule 3 did not extinguish that responsibility, and the liability continued unless displaced by a fresh declaration or specific authorisation. Rule 225 was read as part of the same scheme to show that the rules imposed a continuing and onerous responsibility on the declarant and had to be construed together to reflect legislative intent. The stated conclusion was that Rule 221 liability was not displaced by Rule 3, and the appeals were dismissed.

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Issues: Whether liability under Rule 221 of the Central Excise Rules, 1944 could be avoided on the basis of authorisation under Rule 3 of the Central Excise Rules, 1944, and whether Rule 225 reinforced the declarant's responsibility.

Analysis: Rule 221 was treated as an independent obligation governing the declaration required by the rules. Rule 3 was held to be only an authorisation provision and not one that extinguished the responsibility created by the declaration. The liability continued with the person who signed the declaration until a fresh declaration or specific authorisation displaced it. Rule 225 was also relied upon to show that the scheme of the rules imposed onerous responsibility on the person concerned and that the provisions had to be read together to give effect to legislative intent.

Conclusion: Liability under Rule 221 was not displaced by Rule 3, and the appeals were dismissed.

Ratio Decidendi: A declarant's responsibility under Rule 221 of the Central Excise Rules, 1944 is an independent statutory obligation that is not negated by a mere authorisation under Rule 3, and the relevant rules must be read together to preserve the declarant's continuing liability.

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