These are: (1) Clause 9(a) of the Import Control Order under which the order of cancellation has been made is itself unconstitutional, being violative of the petitioners ' 413 rights under article 19(1)(f) & (g) and article 31 of the Constitution ; (2) The Order of cancellation has been made without compliance with the mandatory requirement of cl. 10 of the Imports Control Order to give the licensee "a reasonable opportunity of being heard "; (3) The first respondent, Mr. Bilgrami, bad no authority in law to make any order under cl. 9 of the Import Control Order; (4) The petitioners have been denied equal protection of laws under article 14 of the Constitution inasmuch as other persons similarly situated have been given a proper opportunity and a personal hearing before taking any action against them, while the petitioners have been denied a proper opportunity to show cause for the cancellation of licences and personal hearing in the matter.