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Issues: Whether the Central Government could, in exercise of revisional jurisdiction under Section 82(2) of the Gold (Control) Act, 1968, examine the correctness of the Administrator's order on the basis of fresh material obtained after the adjudication had been completed.
Analysis: The revisional power under Section 82 is confined to examining the record of the proceedings before the subordinate authority for determining the legality or propriety of the impugned order. The legality of that order must be tested on the material that was before the adjudicating authority, and the revisional authority cannot restart the investigation by relying on evidence or reports obtained later to fill gaps in the case. Finality of investigation and finality of adjudication cannot be mixed, and an order already made after completion of proceedings cannot be subjected to revision on the basis of subsequently procured material.
Conclusion: The Central Government had no jurisdiction to invoke revision on the basis of the later Mint Master's report and subsequent inspection, and the impugned show-cause notice was quashed.
Ratio Decidendi: Revisional jurisdiction to examine the legality or propriety of an adjudication must be exercised only on the record that was before the subordinate authority, and cannot be used to rely on subsequently obtained material to reopen or supplement the original investigation.