What is Double Lock System for Warehouse?
I asked a Customs Officer in charge of a warehouse as to what the double lock system was. He enlightened me, “one key of the warehouse lock would be with the custodian and the other one with the Customs Officer”. Isn't it “Double Lock” system and not “Double Key” system? The officer had no answer. What is the purpose of having a key each with the Customs and the Custodian? Is it an “either or” bank account?
As I understood it, the warehouse is to have two locks – one by the Customs and the other by the custodian and the warehouse could be opened only if both the Custodian and the Customs officer are present together.
A licence issued by the Assistant Commissioner of Central Excise Ahmedabad V Division stipulates – "The warehouse shall be under double lock, i.e one of the Customs department and the other of the licencee. The Customs departments lock should be of the model-Chhub (Godrej, purchased at the expenses of the licencee." So, here the stipulation is two locks, not two keys.
Section 62(3) of the Customs Act stipulates, "the proper officer may cause any warehouse to be locked with the lock of the Customs Department and no person shall remove or break such lock."
But even the Board thinks it should be one lock with two keys. Circular No. 6/2007-Cus dated 22.01.2007 directs, "The concerned Airlines / Custodian warehouse should have double locking arrangement, one key of which will be with the Airlines / custodian and the other with Customs, for storage of transhipment cargo."
STANDING ORDER NO. 03/2004-P dated 24.06.2004 of the Pakistan Customs states, "Bonded warehouses are to be maintained with double lock system, one of the customs and the other of bonder. In quite a few cases, only one lock was found on the doors of the bonded premises, especially the private bonded warehouses, giving uncalled for free access to the licensees, without any check. This aspect should be looked into and necessary action must be taken accordingly."
This is the risk with the Indian Customs too, especially when we are not clear as to whether there should be two locks or two keys. The CBEC should clarify this.