Distinguish between scope of section 155(1) and Section 155(2) of the Customs ACt 1962. Analysis of the protection under Section 155(2) that criminal proceedings are also covered in the word proceedings other than suit . You can rely on customs cases laws and rules of general interpretation for substantiating that criminal proceedings are also covered in the word proceedings other than suit.

 *Distinguishing between Section 155(1) and Section 155(2) of the Customs Act, 1962*

155. Protection of action taken under the Act.

(1)No suit, prosecution or other legal proceedings shall lie against the Central Government or any officer of the Government or a local authority for anything which is done, or intended to be done in good faith, in pursuance of this Act or the rules or regulations.

(2)No proceeding other than a suit shall be commenced against the Central Government or any officer of the Government or a local authority for anything purporting to be done in pursuance of this Act without giving the Central Government or such officer a month's previous notice in writing of the intended proceeding and of the cause thereof, or after the expiration of three months from the accrual of such cause.

Section 155(1) of the Customs Act, 1962, provides protection to the Central Government, its officers, and local authorities against suits and other proceedings, including criminal proceedings. This protection is limited to actions taken in good faith and in pursuance of the Act or any rules ( Section 2(36)  or regulations  Section 2 (35 ) made thereunder.

On the other hand, Section 155(2) provides a broader protection, stating that "no proceedings other than a suit  shall lie against the Central Government or any officer of the Government or local authority for anything purporting to be done in pursuance of this Act without giving the Central Government or such officer a month's previous notice in writing of the intended proceeding and of the cause thereof, or after the expiration of three months from the accrual of such cause.

Analysis of the  protection under Section 155(2) 

We submit that the word "proceedings" in Section 155(2) is broad enough to cover not only civil proceedings but also criminal proceedings. The use of the word "proceedings" without any qualification or limitation indicates that the legislature intended to provide a comprehensive protection to the Central Government, its officers, and local authorities.

. *Rules of General Interpretation*: According to the rules of general interpretation, when a word or phrase is used in a statute without any qualification or limitation, it should be given its broadest meaning. In this case, the word "proceedings" should be interpreted to cover all types of proceedings, including criminal proceedings.

In light of the above, we submit that the protection under Section 155(2) extends to criminal proceedings as well.