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Issues: Whether the plaintiff was the first informant entitled to reward under the customs reward guidelines.
Analysis: The reward scheme was held to be purely ex gratia and dependent on the absolute discretion of the competent authority. It could not be claimed as a matter of right. Entitlement depended on the specificity and accuracy of the information furnished, the risk undertaken, the nature of assistance rendered, and whether the information meaningfully assisted in tracing smuggling activity and those involved. On the facts found, the plaintiff only informed a sepoy that a vessel had stranded and that persons had unloaded goods. He did not identify the smugglers, did not lodge a written complaint, and did not furnish particulars showing the kind of actionable intelligence contemplated by the guidelines.
Conclusion: The plaintiff was not proved to be an informer satisfying the reward guidelines and was not entitled to the claimed reward.