HIRA H. ADVANI ETC. vs STATE OF MAHARASHTRA

The Supreme Court held that statements made before a Customs Officer do not qualify as judicial proceedings under Section 132 of the Evidence Act or Article 20(3) of the Constitution, as a Customs Officer is not a court. The Court clarified that the inquiry under Section 171-A of the Sea Customs Act does not attract the protections afforded to judicial proceedings. The convictions under Section 167(81) of the Sea Customs Act and Section 5 of the Imports and Exports (Control) Act, 1947 were upheld, affirming the lower courts' decisions.