Short-landed cargo was confirmed where seal records were incomplete and survey evidence showed prompt discovery of shortages.

Contemporaneous landing records and survey/destuffing evidence were accepted to determine whether cargo had short-landed after unloading. Where seal numbers were not recorded against the containers, the seals were treated as not intact, and the damaged condition of the goods, together with surveys conducted within a reasonable period and prompt destuffing, supported the inference that shortages were discovered soon after landing. On that basis, the goods were held to have short-landed and the revision application was found to lack merit, leaving the order-in-appeal undisturbed.

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Issues: Whether the impugned cargo had short-landed on account of seals on the containers not being intact and shortages having been discovered within a short period of landing.

Analysis: The order accepted the contemporaneous landing records and survey/destuffing evidence. It held that where seal numbers were not mentioned against the containers, the seals were to be treated as not intact. The finding of damaged condition of goods, the holding of surveys within a reasonable period, and the prompt destuffing of the containers supported the inference that the shortages were discovered soon after unloading.

Conclusion: The goods were held to have short-landed, the revision application was found to lack merit, and the order-in-appeal was sustained.

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