Strict compliance governs export exemption conditions; substantial compliance cannot override objective transitional requirements for non-basmati white rice.

Strict construction applies to export exemptions, and a claimant must satisfy each notified condition fully to fall within the exception. The court treated the berthing, anchoring, and Customs handover requirements as essential, objective and independently verifiable elements of the transitional exemption scheme for non-basmati white rice. Because the appellant did not establish full compliance with those conditions before the stipulated time, the doctrine of substantial compliance could not be used to relax the notification. The exemption was therefore unavailable for the remaining 11,000 MT, and the export prohibition continued to apply.

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Issues: Whether the appellant could invoke the doctrine of substantial compliance to claim exemption from the export prohibition and obtain permission to export 11,000 MT of non-basmati white rice despite not strictly satisfying the exemption conditions in the notification.

Analysis: The export ban on non-basmati white rice was imposed with immediate effect, and the notification carved out only limited, independent exemptions for transitional consignments. The later amendment and the DGFT trade notice clarified that the exemption conditions operate separately and must each be satisfied in entirety. The appellant did not establish full compliance with the relevant conditions concerning berthing and anchoring of the vessel, or handing over the consignment to Customs or entry into the Customs station before the stipulated time. The Court held that these were essential, objective and verifiable requirements forming the substance of the exemption scheme, and that relaxing them on a substantial-compliance basis would convert the notification into a subjective and non-uniform regime. In an exemption case, strict construction applies and the claimant must bring itself clearly within the exception.

Conclusion: The appellant was not entitled to the benefit of substantial compliance and could not claim the exemption for export of the remaining 11,000 MT.

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