Natural justice requires a reasoned licence revocation order with disclosure of relied-upon documents and cross-examination opportunity.

Revocation of a Custom House Agents licence was found unsustainable because the Commissioner issued a non-speaking order that did not address the appellants' reply, objections to the inquiry report, or request for cross-examination. Reliance on the Inquiry Officer's report alone, without a reasoned consideration of the defence and without supplying relied-upon documents, breached the principles of natural justice. The appellate authority set aside the order and remanded the matter for fresh consideration after hearing the appellants, furnishing the documents sought, and allowing cross-examination.

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Issues: Whether the order revoking the Custom House Agents licence was vitiated for being a non-speaking order and for breach of natural justice by not dealing with the appellants' objections, documents and request for cross-examination.

Analysis: The appellate authority found that the Commissioner had merely relied on the Inquiry Officer's report without discussing the appellants' reply to the show cause notice or the specific objections raised against the inquiry. The order itself stated that the Commissioner did not want to elaborate on the details, showing absence of a reasoned treatment of the defence. The authority also noted that the appellants had sought supply of relied-upon documents and cross-examination of witnesses, and that these requests ought to have been considered at the original stage to test the allegations properly.

Conclusion: The order was held to be non-speaking and contrary to the principles of natural justice. It was set aside and the matter was remanded for fresh consideration after hearing the appellants, supplying the relied-upon documents and permitting cross-examination as sought.

Ratio Decidendi: An adjudication that rests only on an inquiry report, without dealing with the defence and without granting a fair opportunity to test adverse material through disclosure and cross-examination, violates natural justice and cannot stand.

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