Vague Customs seizure notice under Section 110 justified interim protection where the basis for blocking the account was unclear.

A seizure notice under the Customs Act, 1962 was treated as falling within Section 110, but its legal basis had to be made clear because seizure for confiscation under Section 110(1) and seizure for evidentiary purposes under Section 110(3) carry different consequences. The notice was found vague and cursory, as it did not clearly disclose the ground for blocking the account or permit a double interpretation. The affected person was entitled to know the substance of the seizure basis, and interim writ protection was justified pending disposal of the rule.

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Issues: Whether an interim writ protection was warranted against a seizure notice issued under the Customs Act, 1962, when the notice did not clearly disclose whether action was taken for confiscation under Section 110(1) or for collection of evidence under Section 110(3).

Analysis: The notice was treated as one issued under Section 110 of the Customs Act, 1962. The distinction between seizure for confiscation under sub-section (1) and seizure for evidentiary purposes under sub-section (3) was material because the legal consequences were different. The notice was found to be cursory and vague, and it did not make clear the basis on which the petitioner's account was being blocked. In such matters, affected persons are entitled to know the substance of the ground for seizure, and the notice should not be left open to double interpretation.

Conclusion: Interim protection was held to be justified, and the petitioner was granted interim relief in respect of its own account pending disposal of the rule.

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