Retraction does not bar reliance on a confession when voluntary and corroborated; natural justice breach requires demonstrated prejudice.

A retracted confessional statement may still be relied upon in adjudication if it was voluntary and is corroborated by surrounding documents and circumstances; here, the appellant's handwritten seized records and related material supported the statement. Refusal to supply English versions of seized documents did not violate natural justice where the documents were authored by the appellant, and denial of cross-examination was not fatal absent demonstrated prejudice, as reasonable opportunity in quasi-judicial proceedings is fact-sensitive. On the evidence, the findings of contravention, confiscation and penalties were sustained because the appellant failed to substantiate the explanation for the seized currency.

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Issues: (i) whether the retracted confessional statement of the appellant could be relied upon in adjudication; (ii) whether refusal to supply English versions of the seized documents and to permit cross-examination amounted to violation of natural justice; and (iii) whether the findings of contravention, confiscation and penalties were sustainable on the evidence.

Issue (i): whether the retracted confessional statement of the appellant could be relied upon in adjudication.

Analysis: A retracted confession is not barred from consideration merely because it has been retracted. The decisive questions are whether the statement was voluntary and whether the inculpatory part is supported by surrounding material. The statement in question was recorded after prolonged non-appearance, and the seized loose sheets were admittedly in the appellant's handwriting. The record also contained corroborative material linking the transactions to the co-appellants.

Conclusion: The retracted confessional statement was admissible and could be acted upon.

Issue (ii): whether refusal to supply English versions of the seized documents and to permit cross-examination amounted to violation of natural justice.

Analysis: The complaint regarding untranslated documents did not carry weight because the documents were authored by the appellant himself. As to cross-examination, a reasonable opportunity in quasi-judicial proceedings depends on the facts and is not an absolute right. No prejudice was shown, and the recovery and ownership of the currency were not in dispute.

Conclusion: No violation of natural justice was made out.

Issue (iii): whether the findings of contravention, confiscation and penalties were sustainable on the evidence.

Analysis: The seized currency was treated as proceeds of illegal foreign exchange dealings, and the appellant failed to produce any credible material to support the explanation for the cash found with him and the co-appellant. The adjudicating authority's conclusions were supported by the statements and seized records, and the penalties were not shown to be excessive or harsh.

Conclusion: The adjudication order, including confiscation and penalties, was sustainable.

Final Conclusion: The appeals were found to be without merit and the adjudication order was upheld in full.

Ratio Decidendi: A retracted confession may be relied upon in adjudication if it is voluntary and is corroborated by surrounding circumstances or documentary material, and cross-examination is not an absolute right in quasi-judicial proceedings absent demonstrated prejudice.

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