Preventive customs seizures in border-proximate inland areas upheld, with prima facie reason to believe standard affirmed and appeal dismissed

Preventive customs powers extend to inland areas proximate to international borders for anti-smuggling interceptions; jurisdictional validity was sustained where interception occurred on a border-adjacent road. The court emphasised that an officer need only possess a prima facie satisfaction or reasonable belief based on contemporaneous material to justify seizure, and absence of elaborate reasons in the seizure memorandum does not vitiate action if grounds appear on record. Domestic-trade assertions are rebuttable after notice and post-seizure procedures must follow; allegations of corruption did not displace the regulatory remedy framework, and the appeal was dismissed on merits.

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Issues: Whether the seizure of goods and vehicle under Section 110(1) of the Customs Act, 1962 at an inland location (Chikanpara) was invalid for want of a disclosed "reason to believe" and for lack of jurisdictional basis.

Analysis: Section 110(1) empowers preventive seizure where a proper officer forms a reasonable belief that goods are liable to confiscation; that belief is assessed from contemporaneous material and circumstances available at the time of interception. Judicial review is limited to determining whether prima facie grounds existed to support the officer's satisfaction and does not permit microscopic re-evaluation of the merits of that belief. Relevant contemporaneous factors include interception proximate to an international border, deviation from usual route, and other suspicious circumstances, together with pending test reports and statements. Absence of detailed expository reasoning in the seizure memo does not automatically invalidate preventive action if prima facie material on record supports the officer's satisfaction. Allegations of mala fides or corruption, while serious, do not compel quashing of seizure where the material circumstances justify non-interference and investigation remains ongoing; such allegations may be pursued through appropriate criminal or disciplinary fora but do not of themselves negate the existence of prima facie grounds for seizure.

Conclusion: The challenge to the seizure succeeds neither on the ground of absence of "reason to believe" nor on jurisdictional grounds; the issue is decided against the appellant and in favour of the Revenue.

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