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    <title>2021 (12) TMI 1025 - DELHI HIGH COURT</title>
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    <description>The Customs Act, 1962 was treated as a complete code for seizure, confiscation, adjudication, release and appeal in customs matters, and the Disposal Manual 2019 was held to operate only within that framework. Section 451 of the Code of Criminal Procedure, 1973 could not be used by the criminal court to direct disposal of goods seized under customs law, because the manual did not create an independent source of CrPC power. The fact that the goods were dry dates with a short shelf life did not justify invoking Section 451 while customs adjudication was still pending; the earlier view that Section 451 does not apply to such customs-seized goods was followed.</description>
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