Extra-statutory renewal conditions cannot override regulations, and forfeiture based on such a public notice is void.

An administrative public notice cannot add a renewal deadline that is inconsistent with the governing Regulations. Where the Regulations required an authorised courier's renewal application to be made before expiry, a notice demanding filing one month earlier had no legal force because it was not authorised by the Act or the Regulations. Any forfeiture of security based on breach of that extra-statutory condition was therefore without authority of law and could not stand. A notice cannot modify or supplement the statutory scheme unless the parent law permits it; action founded on an inconsistent notice is ultra vires and void.

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Issues: Whether a public notice could validly require an authorised courier to apply for renewal of registration one month before expiry, and whether forfeiture of security for non-compliance with that condition was sustainable when the Regulations themselves required only an application before expiry under Regulation 10(3).

Analysis: The Regulations provided that registration of an authorised courier was valid for three years and could be renewed on application made before expiry if performance was satisfactory. The public notice added a further condition requiring renewal application to be filed one month before expiry. As the notice was not authorised by the Act or the Regulations, it could not modify the statutory scheme or override the regulation. A condition introduced through a public notice, inconsistent with the Regulations, had no legal force.

Conclusion: The forfeiture based on breach of the public notice was without authority of law and could not stand. The condition in the public notice was inapplicable, and the appellants succeeded.

Ratio Decidendi: An administrative public notice cannot alter or supplement a statutory regulation unless the parent Act authorises such modification, and any action founded on a notice inconsistent with the regulation is ultra vires and void.

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