Time-bound disciplinary proceedings under customs broker regulations cannot be delayed indefinitely; revocation was invalidated.

Under the Customs Brokers Licensing Regulations, 2013, compliance with the prescribed time limits is an essential condition for valid disciplinary action. Although the charge-sheet was issued within time, the inquiry was completed after an inordinate and unexplained delay, and the revocation order followed long after the statutory period. CESTAT treated this delay as fatal to the legality of the proceedings, applying earlier precedent that a time-bound disciplinary process cannot be extended indefinitely. The revocation of the customs broker licence and forfeiture of the security deposit were therefore held unlawful and set aside.

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Issues: Whether inordinate delay in completing inquiry proceedings under the Customs Brokers Licensing Regulations, 2013 vitiated the revocation of the customs broker licence and forfeiture of the security deposit.

Analysis: The Tribunal held that compliance with the time-frame prescribed by the Regulations is an essential prerequisite for the legality and sanctity of the proceedings. Although the charge-sheet was issued within time, the inquiry itself was completed after an inordinate and unexplained delay, and the revocation order was passed long after the prescribed period. Following earlier precedent, the Tribunal treated such delay as fatal to the disciplinary action.

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

Ratio Decidendi: Where the Regulations prescribe a time-bound disciplinary process for customs broker proceedings, inordinate delay in completing the inquiry and culminating the action renders the revocation invalid.

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