GEORGETOWN – Justice Gino Persaud handed down a major ruling on Friday afternoon, delivering a sweeping victory to businessman and MP Azruddin Mohamed and sharply rebuking the Guyana Revenue Authority (GRA) for repeated delays and procedural abuses throughout the case.
In a decision delivered at 3:00 p.m., Justice Persaud granted the Fixed Date Application originally filed on April 2, 2025, and rejected two late-stage applications by the GRA, describing one of them, filed on November 5—as “an abuse of the court’s process.”
The judge ruled that the GRA’s attempt to link Mohamed’s ongoing U.S. extradition request to the judicial review case was “irrelevant,” noting that the court’s task was strictly to determine whether the imposition of $421,057,712 in taxes and the demand for the surrender of three vehicles were lawful.
Justice Persaud expressed concern that the GRA repeatedly filed new documents as the ruling date approached, despite the matter having been ready for judgment since October. He also dismissed a June 10, 2025 application by the GRA which sought to suspend the case until criminal charges against Mohamed were dismissed, rejecting the claim that ruling on the civil matter risked “inconsistent judgments.”
The court highlighted that the GRA had filed five affidavits, each on different dates, in response to Mohamed’s single affidavit. Justice Persaud said the Civil Procedure Rules do not contemplate such a tactic, reinforcing that the GRA’s approach was improper.
Relying on multiple local precedents cited by Mohamed’s counsel, Justice Persaud ruled that the GRA has no legal authority to conduct post-clearance reassessments once goods have been entered, cleared, and taxes paid. He added that the GRA could not pursue further taxes unless Mohamed is first found guilty of corresponding criminal offences.
Justice Persaud granted every order requested by attorneys Siand Dhurjon and Damien Da Silva on Mohamed’s behalf, including: A declaration that the tax impositions of $371,775,168, $24,641,272, and $24,641,272, totalling $421,057,712, were arbitrary, ultra vires, unreasonable, unfair and unlawful. An order quashing the imposition of those taxes.
An order quashing the requirement that Mohamed surrender his 2020 Lamborghini Aventador SVJ Roadster (PZZ 4000) and two 2021 Toyota Land Cruisers (PAB 3000 and PAB 4000). A strengthened injunction preventing the GRA and its agents from seizing the three vehicles.
An order requiring the GRA to pay $750,000 in costs to Mohamed by December 31, 2025.ATTORNEYS REACTSpeaking after the ruling, attorney Siand Dhurjon said the legal team was “deeply satisfied with a most considered and strong ruling,” noting that the matter had been prolonged by “over 10 attorneys” retained by the GRA.
He also reminded that the GRA still owes Mohamed $300,000 as previously ordered by the Full Court.The GRA was represented by a high-profile battery of lawyers, including: Anand Ramlogan SC, Robin Stoby SC, Sanjeev Datadin, Mohanie Angaloo, Maritha Halley, Judy Stuart, Jason Moore, Fiona Hamilton, Ornise Gordon and Nicklin Belgrave.
