Immediate suspension under licensing regulations can stand without prior hearing when urgent reasons and post-decisional defence safeguards exist.

Regulation 21(2) of the Customs House Agents Licensing Regulation, 1984 authorises immediate interim suspension where urgent action is necessary and an enquiry is pending or contemplated. The High Court held that the Collector could suspend the CHA licence without prior hearing because the order recorded detailed reasons, including prima facie involvement in attempted export of narcotic goods and related lapses. Natural justice was not violated since Regulation 23 provides a later enquiry and opportunity of defence before any final order, so audi alteram partem was satisfied through the post-suspension process. The interim suspension was upheld as a speaking order based on recorded urgency and misconduct.

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Issues: Whether the Collector was empowered to suspend the Customs House Agent licence with immediate effect under Regulation 21(2) of the Customs House Agents Licensing Regulation of 1984, and whether such interim suspension was invalid for want of prior hearing under the principles of natural justice.

Analysis: Regulation 21(2) expressly authorises immediate suspension where immediate action is necessary and an enquiry is pending or contemplated. The order recorded detailed grounds showing a prima facie involvement in attempted export of narcotic goods, failure to obtain authorisation, and other lapses discovered in the course of investigation. Regulation 23 provides the procedure for the subsequent enquiry and opportunity of defence before any final order, so the rule itself contemplates immediate interim action followed by a full hearing later. In those circumstances, the doctrine of audi alteram partem was not attracted so as to invalidate the interim suspension, especially when the order was a speaking order founded on recorded reasons and not on mere subjective satisfaction.

Conclusion: The interim suspension was valid and not contrary to natural justice.

Ratio Decidendi: Where a statutory regulation expressly permits immediate suspension pending a contemplated enquiry and the authority records reasons showing urgency and prima facie misconduct, prior hearing is not before passing the interim order; the requirement of natural justice is satisfied by the post-suspension enquiry procedure.

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