An uncancelled duty-free import licence obtained through fraud...

An uncancelled duty-free import licence obtained through fraud or misrepresentation remains voidable rather than void from inception. Where the licence was genuinely issued, endorsed transferable and not cancelled by the competent authority, a bona fide transferee for value without notice of third-party fraud in export-obligation certification is distinct from the fraudster and cannot be subjected to duty, interest or redemption fine for imports under that licence. The principle that fraud vitiates everything does not displace those rights in this setting. A statutory appeal confined to substantial questions framed at admission cannot be decided on an unframed limitation ground unless an additional question is formally permitted. The duty demand, interest and redemption fine were quashed.