that the said silver coins, silver discs, gold ornaments
and silver ornaments were liable to forfeiture under the
provisions of Sections 27 (1) (a) of the said Ordinance.
On the 12th day of April 1981, Your Petitioners
did write to the Director of Trade, Industry and Customs
Department claiming that the said cargoes were not liable
8.
to forfeiture.
Subsequently, on the 24th day of April 1981,
one Wong Ching Yuet, acting for and on behalf of your
Petitioner and having obtained the power of attorney
from Your Petitioners, served notice on and did write to
the Director of Trade, Industry and Customs Department
claiming that the said cargoes were not liable to forfei-
ture.
9.
On the 22nd day of December, 1981 the said
application for forfeiture was heard by the Learned
Magistrate Mr. D.C. Lee who made an order that the cargoes
be forfeited to the Crown.
10.
On the grounds hereinafter appearing, Your
Peitioners claiming that they have a moral claim in
respect of the said cargoes.
11.
Your Petitioners humbly submit that the offences
of carrying unmanifested cargoes with which they were
convicted were offences of a technical nature. No special
formate is required for a document to comply with the defini-
tion "manifest" under Section 3 of the Import and Export
Ordinance so long as the document contains the particulars
under Regulation 1 of the Import and Export Manifest Notice.
Such particulars as are required by the said regulation are
far from being onerous. Had Your Petitioners been aware of
the requirement of carrying a manifest in relation to the
said cargoes, they could easily have compiled with the