Natural justice in customs valuation requires disclosure of adverse material before confiscation can be sustained.

A customs confiscation order based on appraised value and comparative imports could not stand where the importer was not informed of the specific material relied upon or the basis for fixing the price of the goods. In quasi-judicial proceedings, adverse material must be disclosed and the affected party must be given a fair opportunity to contest it; the possibility that the party could have sought disclosure does not cure the defect when the authority itself relied on undisclosed material. The confiscation order was therefore unsustainable for breach of natural justice, and the petition succeeded.

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Issues: Whether a customs order of confiscation and redemption fine could stand when the authorities relied on material not disclosed to the importer and afforded no opportunity to meet it.

Analysis: The customs authorities proceeded on appraised value and comparative imports said to support that value, but the importer was not informed of the specific material, the other imports relied upon, or the basis on which the price of the goods was fixed. In quasi-judicial proceedings, when an authority proposes to use material against a party, the party must be given notice of that material and an opportunity to contest it. The fact that the party could have asked for disclosure does not cure the defect where the authority itself relied on the material without putting it to notice.

Conclusion: The confiscation order could not be sustained in the absence of disclosure of the adverse material and an opportunity to meet it, and the petition succeeded.

Ratio Decidendi: A quasi-judicial authority cannot base an adverse order on material not disclosed to the affected party without first giving notice and an opportunity to rebut it.

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