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Issues: Whether the Customs authorities could validly seize the same goods again under Section 110(1) of the Customs Act, 1962 after the goods had already been confiscated under Section 111 of the Customs Act, 1962 with an option of redemption on payment of fine.
Analysis: The goods had been the subject of completed adjudication proceedings resulting in confiscation, coupled with a redemption option which was exercised and the goods were released on payment of fine. In that situation, a later attempt to seize the very same goods under Section 110(1) was inconsistent with the earlier final order. If the authorities sought to disturb the earlier order, the proper course was to take steps under Section 129(d) of the Customs Act, 1962 for revival or further proceedings, not to initiate a fresh seizure of goods already dealt with conclusively. The seizure was therefore treated as without authority and a nullity.
Conclusion: The seizure memo dated 15 December 1981 was quashed and set aside, and the petitioners were entitled to return of the bonds and the monitor set.
Final Conclusion: The writ petition succeeded, and the later seizure action was invalid because the goods had already been finally dealt with in the earlier confiscation proceedings.
Ratio Decidendi: Once imported goods have been finally confiscated with an option of redemption on payment of fine and the option is exercised, the Customs authorities cannot in the guise of a fresh seizure proceed against the same goods unless the earlier order is lawfully revived or set aside.