Recorded reason to believe is essential for valid customs seizure; detention without it cannot be sustained.

A seizure under Section 110(1) of the Customs Act is valid only if the proper officer records, or contemporaneously reflects, a reason to believe that the goods are liable to confiscation. Mere detention through panchnamas, without any recorded seizure order or apparent subjective satisfaction, is insufficient to amount to lawful seizure. On that basis, the detention could not be sustained and the writ petition succeeded, with a direction to return the goods to the petitioner forthwith.

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Issues: Whether the customs officers had effected a valid seizure of the goods under Section 110(1) of the Customs Act, 1962, and whether the detention of the goods could be sustained in the absence of a recorded belief that they were liable to confiscation.

Analysis: Section 110(1) permits seizure only where the proper officer has reason to believe that the goods are liable to confiscation. The existence of that subjective satisfaction must appear on the face of the order or contemporaneous record. In the absence of any recorded seizure order showing such satisfaction, mere detention through the panchnamas was insufficient to constitute a valid seizure under the provision.

Conclusion: The seizure was not validly effected under Section 110(1), and the detention of the goods could not be sustained.

Final Conclusion: The writ petition succeeded and the detention of the goods was quashed with a direction to return the goods to the petitioner forthwith.

Ratio Decidendi: A seizure under Section 110(1) of the Customs Act, 1962 is valid only if the proper officer's reason to believe that the goods are liable to confiscation is recorded or otherwise apparent from the seizure action; absent such recorded subjective satisfaction, detention cannot be upheld as a lawful seizure.

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