Customs adjudication cannot decide rival ownership claims to seized goods; statutory jurisdiction remains limited.

Customs adjudicating power cannot be used to resolve rival title claims over seized goods. The dispute concerned competing claims by the exporter, importer and a secured creditor to seized gold jewellery under the Customs Act, but the forum's role was limited to customs proceedings and did not extend to declaring ownership. A judicial direction to decide a representation in accordance with law did not enlarge statutory jurisdiction, because adjudicatory authority must come from the statute itself. As the importer was not even a party to the appeal, any determination of entitlement to the goods was beyond the customs forum's competence, and the finding in favour of M/s. Vee Ess Jewellers was held invalid and inoperative.

---

---

Issues: Whether the customs adjudicating authority had jurisdiction to decide competing claims of title to seized goods and to declare one claimant entitled to the goods.

Analysis: The seizure and proposed confiscation proceedings arose under the Customs Act, but the dispute before the authority extended to rival ownership claims between the exporter, the importer and a secured creditor. The Court held that the High Court's earlier direction to decide the representation in accordance with law did not confer jurisdiction to adjudicate title disputes. Adjudicatory power is a creature of statute and cannot be inferred from a judicial direction. Since the importer was not even a party to the appeal, any determination of entitlement to the goods would in any event be beyond the customs forum's competence.

Conclusion: The authority had no jurisdiction to decide competing claims of title to the seized gold jewellery, and the finding declaring the goods to belong to M/s. Vee Ess Jewellers was invalid and inoperative in favour of the appellant.

---