Immediate action requirement governs suspension of a Custom House Agent's licence under Regulation 21(2), and the order was quashed.

A suspension of a Custom House Agent's licence under Regulation 21(2) is valid only where the order itself shows that immediate action was necessary and that an enquiry was pending or contemplated. The High Court found that the impugned suspension order did not disclose any need for immediate action, and the recorded facts on the face of the order did not justify such action. On that basis, the suspension was held unsustainable and was quashed, reaffirming that the statutory precondition for emergency suspension must appear from the order itself.

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Issues: Whether the suspension of a Custom House Agent's licence under Regulation 21(2) of the Custom House Agents Licensing Regulations, 1984 was valid when the order did not disclose that immediate action was necessary.

Analysis: Regulation 21(2) permits suspension only in appropriate cases where immediate action is necessary and an enquiry is pending or contemplated. The suspension order must disclose the circumstances showing the need for immediate action. Here, the impugned order did not state that immediate action was required and the recorded facts did not justify such action on its face.

Conclusion: The suspension order was unsustainable and was quashed.

Final Conclusion: The challenge to the suspension succeeded, and the licence suspension could not stand under Regulation 21(2) on the facts recorded in the order.

Ratio Decidendi: A suspension of a Custom House Agent's licence under Regulation 21(2) is valid only if the order itself discloses that immediate action was necessary and the circumstances warranting such action.

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