Customs reward eligibility turns on the guidelines in force on the seizure date, not later exclusions or ceilings.

Eligibility under a customs reward scheme must be tested strictly against the guidelines in force on the date of seizure. The exclusion for officers above Assistant Collector level applied only within the specified customs or excise hierarchy and did not bar a member of the Indian Police Service, who fell outside that classification; the rejection of the first claim was therefore unsustainable. A later ceiling of Rs. one lakh per officer could not be applied retrospectively where the governing guidelines at the relevant time contained no such limit; the second claim had to be reconsidered afresh under the earlier guidelines. The rejection orders were accordingly set aside.

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Issues: (i) Whether a member of the Indian Police Service was eligible for reward under the applicable customs reward guidelines notwithstanding the objection that officers above Assistant Collector level were excluded; (ii) whether the claim for a higher reward by the Circle Inspector could be rejected on the supposed ceiling of Rs. one lakh per officer.

Issue (i): Whether a member of the Indian Police Service was eligible for reward under the applicable customs reward guidelines notwithstanding the objection that officers above Assistant Collector level were excluded.

Analysis: The reward scheme treated the payment as ex gratia, but eligibility had to be determined strictly by the guidelines then in force. The exclusion in clause 7.2 was confined to Group A officers above the specified level in the concerned customs or excise hierarchy. A member of the Indian Police Service, being part of an All India Service and not falling within that classification, was not covered by the bar. The clause also did not justify excluding officers from other departments by a supposed equivalence to Assistant Collector or Assistant Director. The contrary administrative understanding was further contradicted by instances where rewards had in fact been granted to members of All India Services in similar seizure operations.

Conclusion: The petitioner was eligible for reward and the rejection orders were unsustainable.

Issue (ii): Whether the claim for a higher reward by the Circle Inspector could be rejected on the supposed ceiling of Rs. one lakh per officer.

Analysis: The applicable guidelines in force on the date of seizure did not prescribe any ceiling of Rs. one lakh for an individual officer. That limit appeared only in a later order issued after the seizure and could not govern the claim. The matter therefore had to be reconsidered under the earlier guidelines and the quantum had to be fixed afresh on that basis.

Conclusion: The rejection based on the supposed ceiling was incorrect and required fresh consideration.

Final Conclusion: The challenges succeeded to the extent that the first petitioner was declared eligible for reward and the second petitioner's claim was directed to be reconsidered under the earlier guidelines, with the impugned rejection orders set aside accordingly.

Ratio Decidendi: Eligibility under a reward scheme must be determined strictly by the governing guidelines as they stand on the relevant date, and an administrative authority cannot impose an exclusion or monetary ceiling not found in those guidelines.

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