Timely customs licence revocation proceedings required merits review after compliance with the binding completion deadline.

Customs house agent licence revocation proceedings under Regulation 22 were required to be completed, including the Commissioner's order, by the stipulated deadline. The inquiry report, disagreement memorandum and revocation order were completed within that period. The Tribunal treated the proceedings as delayed without considering the binding time direction or compliance with it, and set aside revocation without examining the merits. The High Court therefore found no delay, set aside the Tribunal's order, and remanded the agent's appeal for a merits-based decision in accordance with law.

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Issues: Whether the Tribunal could set aside revocation of the customs house agent licence solely for alleged delay in the proceedings under the Customs House Agents Licensing Regulations, 2004, despite the High Court's stipulated time limit for completing those proceedings.

Analysis: The prior High Court direction required completion of the process under Regulation 22, including the Commissioner's order, by 31 October 2013. The inquiry report, disagreement memorandum and revocation order were all completed within that deadline. The Tribunal had not addressed the merits and had allowed the appeal solely on an assumed unexplained delay, without accounting for that binding direction and compliance with it.

Conclusion: There was no delay in completing the proceedings; the Tribunal's order was set aside and the customs house agent's appeal was remanded for decision on merits in accordance with law.

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