Most Akin Test: combined laboratory testing across required parameters supports classification as ADF/HFHSD and upholds seizure.

Laboratory reports cumulatively covering the required 21 parameters were applied to determine classification; using the Supreme Court-endorsed "most akin" test the imported consignments were found to be most akin to Automotive Diesel Fuel/High-Speed Diesel (adulterated HFHSD), with laboratory opinion of adulteration and non-conformity on flash point supporting that classification, and seizures under customs seizure provisions were upheld. Tests split between CRCL and MRPL were held permissible where samples were properly drawn, testing covered all required parameters and no challenge was made to laboratory competence or mala fides; combined reports were therefore reliable for classification and seizure.

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Issues: (i) Whether the seized consignments of industrial oil are correctly classifiable as Automotive Diesel Fuel (ADF) / High-Speed Diesel (HFHSD) and whether the seizures under Section 110 of the Customs Act, 1962 are justified; (ii) Whether samples tested in more than one laboratory (CRCL and MRPL) and combined test results complying with the Supreme Court's directions (testing of 21 parameters) can be relied upon for classification and seizure.

Issue (i): Whether the seized consignments are ADF/HFHSD and whether seizure is justified.

Analysis: The laboratory reports collectively cover the 21 parameters; CRCL recorded the sample as mainly diesel fraction (95-98%), opined adulteration with lighter hydrocarbons and that the sample is most akin to HFHSD/adulterated HFHSD; MRPL testing shows conformity with multiple parameters of IS 1460:2025 and IS 16861:2018 but failure on flash point and some other parameters. The definition of adulteration under Section 2(a) of the Malpractices Order, 2005 applies where foreign substances cause non-conformity with BIS specifications. The Supreme Court's guidance in Gastrade International requires testing of all 21 parameters, attention to flash point, and application of the "most akin" test for classification; those principles are applied to the combined reports here.

Conclusion: The consignments are held to be most akin to ADF/HFHSD (adulterated HFHSD) and the seizures under Section 110 of the Customs Act, 1962 are justified; conclusion is against the importers.

Issue (ii): Whether tests from multiple laboratories can be relied upon and whether conducting tests in more than one laboratory vitiates the results.

Analysis: The testing in two laboratories cumulatively covers the 21 parameters required by the Supreme Court; samples were drawn properly and testing was conducted in presence of representatives; the fact that different parameters were tested in different competent laboratories does not invalidate results where combined testing conforms to the Supreme Court's directions and the laboratories' reports are not challenged on competence or mala fides.

Conclusion: Tests conducted across CRCL and MRPL are permissible and may be relied upon for classification; reliance on combined laboratory reports is in favour of the respondents.

Final Conclusion: Applying the legal requirement to test all 21 parameters and the "most akin" test to the combined laboratory findings, the classification of the imported product as ADF/HFHSD is sustainable and the seizure is not to be set aside; the writ petitions are dismissed.

Ratio Decidendi: Where technical classification of imported petroleum products with confiscatory consequences is in issue, combined laboratory testing covering all 21 parameters required by the relevant IS specifications is mandatory and the goods must be classified by applying the "most akin" test; unambiguous laboratory opinion that the sample is most akin to a restricted petroleum product and evidence of adulteration justify seizure under the Customs Act.

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