Licence renewal after expiry is not maintainable where the regulation permits renewal only before the licence lapses.

A renewal application for a custom house agents licence filed after the expiry of the renewed licence period was not maintainable under Regulation 13 of the Custom House Agents Licensing Regulations, 1965. The regulation fixes the licence validity period and permits renewal only on an application made before expiry of the relevant period. A belated application is outside the scheme of the regulation, and allowing it would amount to rewriting the provision and enlarging the authority's jurisdiction beyond what is expressly conferred. The refusal to renew the licence was therefore valid, and the challenge failed.

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Issues: Whether a renewal application for a custom house agents licence made after the expiry of the renewed licence period could be entertained under Regulation 13 of the Custom House Agents Licensing Regulations, 1965.

Analysis: Regulation 13 fixes the period of validity of the licence and permits renewal only on an application made before expiry of the relevant licence period. The provision governing renewal does not contemplate an application made after the licence has already lapsed. The wording of the regulation does not support a construction under which subsequent renewals may be sought after expiry, and such an interpretation would amount to rewriting the regulation and enlarging the authority's jurisdiction beyond what has been expressly conferred.

Conclusion: The renewal application made after expiry was not maintainable and the refusal to renew the licence was /valid; the challenge failed.

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