Licensing rights under customs regulations do not vest from a past qualifying exam when the governing scheme later changes.

A pass under the Customs House Agents Licensing Regulations, 1984 did not create an accrued right to obtain a licence after the Customs House Agents Licensing Regulations, 2004 came into force. The 2004 regime changed the eligibility criteria and syllabus, so licensing had to satisfy the requirements then in force. The savings language in the 2004 Regulations and Section 159-A of the Customs Act, 1962 protected only accrued rights, liabilities, and proceedings, not a mere expectation or liberty to apply. Vested right, legitimate expectation, and promissory estoppel could not override the statutory scheme, and no parity or licence entitlement arose from the old examination.

---

---

Issues: Whether persons who had passed the qualifying examination under the Customs House Agents Licensing Regulations, 1984, but had not obtained a licence before the Customs House Agents Licensing Regulations, 2004 came into force, could a right to be treated as qualified under the 2004 Regulations and obtain a licence on the basis of the old examination.

Analysis: A pass under the 1984 Regulations was only an eligibility to apply for a regular licence and did not crystallise into an accrued right to obtain a licence. The regulatory scheme under the 2004 Regulations materially altered both the eligibility criteria and the syllabus, and the issuance of licences remained dependent on the regulatory requirements then in force. The savings language in the preamble to the 2004 Regulations and Section 159-A of the Customs Act, 1962 protected only rights, liabilities, and proceedings already accrued or initiated; it did not preserve a mere hope or liberty to apply for a future licence. The doctrine of vested right, legitimate expectation, and promissory estoppel could not override the statutory regime or compel the authorities to treat the old examination as equivalent to the new one.

Conclusion: The claim was rejected, and the appellants were held not entitled to any licence or parity based on the 1984 examination.

---