Repeated customs broker licence revocation and security deposit forfeiture cannot overlap; reconsideration required after proper notice.

Repeated revocation of the same customs broker licence and repeated forfeiture of the same security deposit under the Customs Brokers Licensing Regulations, 2018 was treated as untenable where successive proceedings overlapped and imposed the same disciplinary consequences. The appellate forum held that such overlapping, repetitive action could not stand and required reconsideration with proper notice. The impugned orders were set aside and the matter was remanded to the licensing authority to proceed with only one revocation action, discard the other three proceedings, or decide all four together after due notice.

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Issues: Whether four separate orders revoking the same customs broker licence and forfeiting the same security deposit under the Customs Brokers Licensing Regulations, 2018 could be sustained, and what consequential relief should follow.

Analysis: The licence had been revoked and the security deposit forfeited in successive proceedings within a short span, each invoking breach of Regulation 10 of the Customs Brokers Licensing Regulations, 2018 and imposing the same consequences under Regulations 14 and 18. The repeated extinguishment of the same licence and security deposit was found to be logically untenable and an unsound approach to disciplinary action, especially when the later orders overlapped with earlier subsisting orders. The appellate forum held that such overlapping and repetitive action could not be permitted to stand and that the matter required reconsideration with proper notice.

Conclusion: The impugned orders were set aside and the proceedings were remanded to the licensing authority to decide revocation in respect of one proceeding and discard the other three, or to decide all four together after due notice to the appellant.

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