Promissory estoppel cannot bar withdrawal of customs exemption notifications issued in public interest under sovereign legislative power.

Customs exemption notifications issued under Section 25(1) of the Customs Act, 1962 in public interest were treated as exercises of sovereign and legislative power. A prior Full Bench ruling was applied to hold that withdrawal or amendment of such exemptions during their currency could not be challenged on promissory estoppel, and that withdrawal of customs duty exemption did not violate Article 19(1)(g). The challenge to the later customs notification therefore failed, and the relief sought by the petitioners was rejected.

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Issues: Whether the withdrawal or amendment of a customs exemption notification during its currency could be challenged on the basis of promissory estoppel and Article 19(1)(g) of the Constitution of India.

Analysis: The notifications were issued under Section 25(1) of the Customs Act, 1962 in public interest. A prior Full Bench ruling had held that such notifications, being issued in the exercise of sovereign and legislative power, were not open to judicial review on the ground of promissory estoppel. It had also been held that withdrawal of customs duty exemption did not infringe the freedom to carry on trade and business.

Conclusion: The challenge to the subsequent customs notification failed and the relief sought by the petitioners was rejected.

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