Natural justice in licence suspension requires disclosure of grounds; reference fails without a substantial question of law.

A show cause notice before suspension of a Customs House Agent's licence was treated as necessary in light of natural justice, even where Regulation 21(2) did not expressly state a notice requirement. The Tribunal also held that Regulation 21(2) did not exclude the operation of Regulation 23, and that a quasi-judicial authority must disclose the grounds for adverse action before acting. The Revenue's request for reference failed because no substantial question of law was shown, so reference to the High Court was not warranted and the Tribunal's remand order remained intact.

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Issues: Whether a show cause notice to a Customs House Agent was mandatory before suspension of licence under Regulation 21(2) of the CHA Licensing Regulations, 1984, and whether a reference to the High Court arose from the Tribunal's order.

Analysis: The application for reference was examined in the context of the Tribunal's earlier view that Regulation 21(2) did not exclude the application of Regulation 23. The order also proceeded on the principle that, even where no express notice requirement is stated, a quasi-judicial authority must disclose the grounds before taking adverse action. The request for reference was found to be unsupported, as no adequate justification was shown to demonstrate that a substantial question of law arose from the impugned order.

Conclusion: A reference was not warranted and the requirement to show cause before suspension was left undisturbed.

Final Conclusion: The Revenue's reference application failed, and the Tribunal's order remanding the matter remained intact.

Ratio Decidendi: A reference to the High Court requires a substantial question of law, and adverse action by a quasi-judicial authority must comply with the disclosure requirements of natural justice even when no express notice provision is stated.

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