Revenue jurisdiction bar and exclusive customs remedies prevented a civil suit challenging confiscation and penalty orders.

The High Court's original civil jurisdiction was excluded in revenue matters, so a suit challenging customs seizure, confiscation, and penalty orders was barred because those acts concerned collection of revenue. The Court also applied the principle that where a special statute creates a right and provides an exclusive appeal and revision mechanism, that remedy is final and cannot be supplemented by a civil suit. Since the customs orders were taken through the statutory scheme, they were not open to fresh civil challenge, and civil relief against the confiscation order was unavailable.

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Issues: (i) Whether the Original Side of the High Court had jurisdiction to entertain a suit challenging customs confiscation and penalty orders as a matter concerning the revenue. (ii) Whether, in view of the Sea Customs Act, the statutory appeal and revision scheme made the administrative orders final and barred a civil suit.

Issue (i): Whether the Original Side of the High Court had jurisdiction to entertain a suit challenging customs confiscation and penalty orders as a matter concerning the revenue.

Analysis: The revenue bar under the applicable Government of India enactments was treated as an express restriction on the High Court's original civil jurisdiction in matters concerning revenue and acts done in collection thereof. The customs seizure, confiscation, and penalty proceedings were held to fall within that field. The absence of mala fides or a patent departure from the statutory scheme did not take the matter outside the bar, and an inquiry into the legality or correctness of the customs authorities' acts could not be used to avoid the jurisdictional prohibition.

Conclusion: The High Court had no jurisdiction to entertain the suit on the ground that it concerned the revenue and acts done in its collection.

Issue (ii): Whether, in view of the Sea Customs Act, the statutory appeal and revision scheme made the administrative orders final and barred a civil suit.

Analysis: The Sea Customs Act provided a specific mechanism of appeal to the Chief Customs Authority and revision by the Governor-General in Council. The statute declared that orders passed in appeal were final subject to revision. Applying the principle that where a statute creates a right and prescribes a special remedy that remedy is exclusive, the Court held that a party who had availed and exhausted the statutory remedies could not subsequently pursue a civil suit to impeach the orders. The revisional order did not open the matter to a fresh civil challenge.

Conclusion: The statutory orders were not open to challenge by civil suit, and the remedy provided by the Act was exclusive and final.

Final Conclusion: The suit was barred both by the revenue jurisdiction restriction and by the finality attached to the statutory customs remedies, so the plaintiff could not obtain civil relief against the confiscation order.

Ratio Decidendi: A civil court's original jurisdiction is excluded in revenue matters and in acts done in revenue collection, and where a special statute provides an exclusive appellate and revisional mechanism with finality attached to its orders, that statutory remedy cannot be supplemented by a civil suit.

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