Strict construction of customs notifications excludes viscose rayon yarn from the term synthetic yarn, defeating confiscation and penalty.

A specific customs notification referring only to "synthetic yarn" and metallised yarn was strictly construed and not expanded to cover all man-made fibres. Because viscose rayon filament yarn is a cellulosic fibre and not synthetic yarn in the non-cellulosic sense, it did not fall within the notified item. The distinction between synthetic, man-made and artificial yarn was material to scope, and the separate wording of the notification confirmed that broader fibre categories were not intended. On that construction, confiscation and penalty were not sustainable.

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Issues: Whether 100% viscose rayon filament yarn fell within the expression "synthetic yarn" notified for the purpose of Chapter IV-A of the Customs Act, 1962, so as to attract confiscation and penalty.

Analysis: The notification specified only "synthetic yarn and metallised yarn" and did not use the broader expressions "man-made yarn" or "artificial yarn". The distinction between synthetic yarn and other categories of man-made fibres was material, because rayon is a cellulosic fibre, whereas synthetic yarn falls within the non-cellulosic category. The phrase used in a prohibition or notification had to be strictly construed, and the separate mention of synthetic yarn and metallised yarn also showed that the notification was not intended to cover all kinds of man-made fibre.

Conclusion: Viscose rayon yarn was not covered by the notified item "synthetic yarn", and the confiscation and penalty were not sustainable.

Ratio Decidendi: A specific notification imposing prohibition or liability must be strictly construed, and an expression such as "synthetic yarn" cannot be enlarged to include every form of man-made or artificial yarn unless the notification clearly so provides.

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