Binding disciplinary timelines can vitiate customs broker licence revocation when proceedings are concluded far beyond the prescribed period.

Binding timelines for completing customs broker licence revocation proceedings were treated as essential to the validity of punitive action. Although the charge-sheet was issued within time, the inquiry and final order were completed well beyond the prescribed period. The Tribunal held that such inordinate delay could not be excused by the seriousness of the alleged misconduct, because compliance with the regulatory procedure was itself necessary to sustain revocation and related forfeiture. The delay therefore rendered the proceedings legally unsustainable, and the revocation of the licence and forfeiture of the security deposit were set aside without remand.

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Issues: Whether inordinate delay in completing customs broker licence revocation proceedings under the prescribed regulatory timeline vitiated the revocation order and forfeiture of security deposit.

Analysis: The regulatory time-frame for completing disciplinary proceedings was treated as an essential condition for the validity of action against a customs broker. Although the charge-sheet was issued within time, the inquiry and finalisation of the proceedings were completed far beyond the stipulated period. The Tribunal held that the disciplinary authority's delay in concluding the inquiry could not be justified by reference to the gravity of the alleged misconduct, because compliance with the prescribed procedure itself was necessary to sustain the punitive action. The delay was therefore a procedural irregularity that affected the legality of the revocation proceedings, and remand was held unnecessary.

Conclusion: The delay vitiated the proceedings, and the revocation of the licence and forfeiture of the security deposit were set aside in favour of the appellant.

Ratio Decidendi: Where the relevant disciplinary regulations prescribe a binding timeline for completion of revocation proceedings, inordinate non-compliance with that timeline renders the resulting punitive order legally unsustainable.

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