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Oral show-cause notice under customs law can preclude automatic release of detained gold pending factual adjudication.

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....Under the Customs Act, the absence of a separate written show-cause notice within the period contemplated for seizure does not by itself require unconditional release of detained gold bars, because an oral notice may be given at the concerned person's request. Whether an oral notice was actually given, whether grounds were communicated, and whether statutory notice requirements were met depends on the contemporaneous record. Challenges to the voluntariness and evidentiary value of a statement involve disputed factual matters requiring evidentiary assessment. Unconditional release was therefore not directed; the competent adjudicating authority must provide a personal hearing and determine the notice-compliance and statement objections within the stipulated period.....