GASTRADE INTERNATIONAL [APPELLANT (S)] Vs. COMMISSIONER OF CUSTOMS, KANDLA [RESPONDENT(S)]
CIVIL APPEAL @ SPECIAL LEAVE PETITION (CIVIL) NO. 6470 OF 2022
(2JB, B.V. NAGARATHNA and SINGH JJ., delivered by NONGMEIKAPAM KOTISWAR SINGH, J.)
The Supreme Court of India has reiterated that expert opinions, however authoritative, are not binding on courts but merely serve as relevant material for judicial consideration. This observation was made in a recent judgment concerning the classification of imported goods under Section 45 of the Indian Evidence Act, 1872.
The case involved a dispute over whether certain imported goods should be classified as Base Oil, as claimed by the importers, or as High-Speed Diesel (HSD), as determined by the Customs Authorities. The Directorate of Revenue Intelligence (DRI) seized the imported cargo, asserting that it was HSD, which is a restricted commodity under Indian trade laws. The High Court upheld the Customs Department’s classification, prompting the importers to challenge the ruling before the Supreme Court.
The Supreme Court, comprising Justices B.V. Nagarathna and N. Kotiswar Singh, acknowledged that while courts generally rely on expert opinions due to their scientific nature, they must scrutinize such opinions when ambiguities, lack of clarity, or inadequacies exist. The Court emphasized that expert conclusions should not be blindly accepted without proper evaluation, especially when the findings are inconclusive.
In the present case, the expert reports and laboratory test results did not categorically classify the imported goods as HSD. Instead, they merely indicated that the goods conformed to certain parameters of HSD under IS 1460:2005. The Court held that mere conformance to some specifications does not equate to a definitive classification as HSD. Furthermore, it stressed that in cases involving technical or scientific parameters with legal and financial consequences, the standard of proof must be higher than mere probability.
The Supreme Court clarified that the correct approach to classification should be based on whether the goods in question are “most akin” to the specified categories under tariff laws. It found that the expert reports failed to definitively conclude that the imported goods were “most akin” to HSD. Given this lack of certainty, the Court deemed it appropriate to grant the benefit of the doubt to the importers.
The Court also noted that ordering a fresh round of testing and expert opinions would be unnecessary, given the inconclusive nature of the existing evidence. Instead, it directed the authorities to ensure that future laboratory tests comprehensively examine all necessary parameters before classifying imported goods.
By allowing the appeals and setting aside the High Court’s decision, the Supreme Court reinforced the principle that expert opinions, while valuable, cannot override judicial scrutiny. The ruling underscores the necessity of precise and conclusive evidence when making legal determinations based on scientific findings. It also establishes the importance of the “most akin” test for classification under Indian customs laws, ensuring a more structured approach in future disputes.
