Customs Broker verification duty under Regulation 10(n) is met by reliable documentary checks, not physical surveillance of exporters.

Regulation 10(n) requires a Customs Broker to verify the IEC, GSTIN, client identity and functioning through reliable, independent and authentic documents or information. The duty is satisfied by documentary and online verification where the materials are not shown to be forged or false; it does not extend to physical inspection of the client's premises or a roving inquiry into the genuineness of government registrations. Later non-traceability of the exporter, without proof that the furnished documents were fake or that the exports were otherwise illegal, does not by itself establish a breach. Continuous surveillance over the client's subsequent conduct is not required.

---

---

Issues: Whether the Customs Broker violated Regulation 10(n) of the Customs Brokers Licensing Regulations, 2018 by failing to verify the IEC, GSTIN, identity and functioning of the exporters at the declared address, and whether revocation of licence, forfeiture of security deposit and penalty were sustainable.

Analysis: Regulation 10(n) obliges a Customs Broker to verify the correctness of the IEC and GSTIN, and the identity and functioning of the client, by using reliable, independent and authentic documents, data or information. The obligation does not require the Customs Broker to conduct a physical inspection of the client's premises or to undertake a roving investigation into the genuineness of government-issued registrations. Once the IEC and GSTIN are verified through available documentary and online means, and there is no evidence that those documents are forged or false, the statutory duty stands discharged. The mere subsequent non-traceability of exporters, without material showing that the documents furnished to the Customs Broker were fake or that the exports were otherwise illegal, does not establish a breach of Regulation 10(n). The principle that a Customs Broker is not required to keep continuous surveillance over the client's later functioning also applies.

Conclusion: The finding of violation of Regulation 10(n) was unsustainable, and the revocation of licence, forfeiture of security deposit and penalty were liable to be set aside.

Ratio Decidendi: Verification under Regulation 10(n) is satisfied when a Customs Broker checks the authenticity of IEC, GSTIN and client identity through reliable independent material; it does not extend to physical verification of premises or to ensuring the continuing traceability or conduct of the exporter.

---