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citation codes
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  • Tobacco Act by the Central Excises and Salt Act, 1944. Thereupon, the Kerala State Legislature passed the Validation Act 9 of 1964 (called Luxury Tax Act, for short)
  • provisions of Article 301 of the Constitution.
  • provisions of Order 47, Rule 1 of the CPC
  • Rule 1 of Order 47 of the CPC.
  • Order 47, Rule 1 of the CPC
  • Section 4 of the 1952 Act
  • Tobacco Act 1 of 1087 M.E
  • provisions of Order 47,
  • Order 47, Rule 1
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Cites
Cited by
Citation Codes
Equivalent Citations
citation codes
Case Number
Advocates
Judges
Acts
  • Tobacco Act by the Central Excises and Salt Act, 1944. Thereupon, the Kerala State Legislature passed the Validation Act 9 of 1964 (called Luxury Tax Act, for short)
  • provisions of Article 301 of the Constitution.
  • provisions of Order 47, Rule 1 of the CPC
  • Rule 1 of Order 47 of the CPC.
  • Order 47, Rule 1 of the CPC
  • Section 4 of the 1952 Act
  • Tobacco Act 1 of 1087 M.E
  • provisions of Order 47,
  • Order 47, Rule 1
Smart Summary

Structured Summary of the Court's Opinion

Factual and Procedural Background

On 1-1-1969 a Single Judge delivered judgment in O.P. No. 390 of 1567 allowing the petition and directing refund of Rs. 30,500 collected as licence-fee under the Travancore Tobacco Act for the years 1952–1957. The levy and collection of the tobacco tax had previously been declared illegal in Abdulkhader's case on the ground that the rules authorising the levy had no independent existence after implied repeal by the Central Excises and Salt Act, 1944.

The Kerala State Legislature then enacted Validation Act 9 of 1964 (referred to as the Luxury Tax Act) validating the levy as a tax on luxuries. This Validation Act was challenged. Initially a learned Judge sustained the Validation Act; a Division Bench of this Court (Writ Appeal No. 5070 of 1965 etc.) held on 3-10-1966 that it violated Article 301 of the Constitution. The State appealed to the Supreme Court, which set aside the Division Bench decision and remanded the matter for fresh investigation whether the levy offended Article 301 (Supreme Court judgment dated 30-7-1969). After remand, a Division Bench of this Court sustained the validity of the Act by judgment on 15-10-1970.

The State filed the present application for review on 18-8-1971, seeking review of the 1-1-1969 judgment on the ground that subsequent decisions (including the Supreme Court's pronouncement and the later Division Bench ruling) altered the legal landscape in the State's favour. The Government Pleader sought review under Order 47, Rule 1 of the Civil Procedure Code and under the inherent powers of the Court. The application for condoning delay in filing the review was allowed.

Legal Issues Presented

  1. Whether the State is entitled to have the judgment of 1-1-1969 reviewed.
  2. If entitlement to review exists, whether there are adequate grounds to allow the application (specifically, whether subsequent binding decisions constitute grounds for review under Order 47, Rule 1 CPC or under the Court's inherent powers).

Arguments of the Parties

State / Government Pleader

  • Invoked Order 47, Rule 1 CPC (and the Court's inherent powers) to seek review of the 1-1-1969 judgment.
  • Relied on the authority of S.A.L. Naravan Row v. Ishwarlal Bhaewandas to contend that proceedings under Article 226 are "civil proceedings" for the purposes of Article 133 and thus attract Order 47.
  • Argued that a subsequent binding decision (the Supreme Court decision of 30-7-1969 and the later Division Bench decision of 15-10-1970) proclaims the law as it always was and therefore operates retrospectively; consequently, the subsequent decision should be treated like retrospective legislation and constitute a ground for review (i.e., discovery of a new and important matter or an error apparent on the face of the record).

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Abdulkhader's case (1962 Ker LJ 625 : AIR 1962 SC 922) Declared the levy and collection of tobacco tax illegal because the rules authorising the levy had no independent existence after implied repeal. Used as factual and legal background for the earlier Single Judge's refund order dated 1-1-1969.
State of Kerala v. A.B. Abdulkhadir (1969 Ker LT 649 : (1969) 2 SCC 363 : AIR 1970 SC 1912) Supreme Court set aside Division Bench decision and remanded the matter for fresh investigation regarding Article 301. Cited to explain the sequence leading to the remand and subsequent Division Bench judgment sustaining the legislation.
Abdulkhadir v. State of Kerala (1971 Ker LJ 4 : 1971 Tax LR 512) Division Bench judgment sustaining the validity of the Validation Act after remand. Shown as a later authoritative ruling relied on by the State to support its request for review.
S.A.L. Naravan Row v. Ishwarlal Bhaewandas (AIR 1965 SC 1318 : 57 ITR 149) Held proceedings under Article 226 to be "civil proceedings" for the purposes of Article 133 (thus potentially attracting review procedures). Invoked by the Government Pleader to argue that Order 47 is applicable to Article 226 proceedings; cited by the Court as part of the State's submissions.
Chenchanna Naidu v. Praia Seva Transports Ltd. (AIR 1953 Mad 39) Expressly ruled that the provision (relating to review procedures) would be attracted. Referenced by the Court as an authority referred to and followed in later cases supporting the applicability of Order 47 in certain contexts.
Dilip Nath Sen v. Certificate Officer (AIR 1962 Cal 346) Followed the Calcutta decision on applicability of review procedure. Cited by the Court as part of the chain of authorities relied upon to support Order 47 applicability in some precedents.
Income-tax Officer, Masulipatnam v. K. Srinivasa Rao (AIR 1969 Andh Pra 441) Another decision following the line that Order 47 may apply. Referred to by the Court as part of the jurisprudential background on review procedure.
S.P. Awate v. C.P. Fernandes (AIR 1959 Bom 466) Discussed in earlier decisions (Chagla, C.J.) regarding the Court's power to review Article 226 orders. Mentioned as a source considered by subsequent High Court decisions on reviewability of Article 226 orders.
Pathrose v. Kuttan alias Sankaran Nair (1969 KLT 15 : AIR 1969 Ker 186) Held that a subsequent binding authority taking a different view is a good ground for review; relied on both "new and important matter" and "error apparent on the face of the record". Discussed at length; Court declined to accept Pathrose's reasoning as laying down correct law for the present circumstances.
Chandrasekharan Nair v. Purushothaman Nair (1969 Ker LT 686) Followed Pathrose and stated that a subsequent decision is discovery of a new and important matter and an antecedent decision is an error apparent on the face of the record. Noted by the Court but rejected as not representing the correct principle applicable in the present case.
State of Kerala v. Kesavan Vadhyan Namboodiri (1969 Ker LJ 450) Held that a subsequent binding decision was not a ground for review under inherent powers. Referred to as an authority inconsistent with Pathrose; Court aligned with this restrictive view on subsequent decisions.
Waghela Raisangii Shivsangji v. Shaik Masludin (1889 ILR 13 Bom 330) Held that a Privy Council decision reversing the High Court could be "a new and important matter" under old Code provisions. Noted by the Court but said to rest on special facts and to have been shaken by later Privy Council authority.
Rajah Kotagiri Venkata Subbamma Rao v. Raiah Vellanki Venkatrama Rao ((1900) 27 Ind App 197 : ILR 24 Mad 1 (PC)) Lord Davey's statement that review for "new and important matter" must relate to something existing at date of decree and that subsequence events do not authorise review. Relied upon by the Court as authoritative support that a subsequent event or subsequent decision is generally not a ground for review.
Roy Meghrai v. Beeioy Govind Burral (referenced) Mentioned in the context of interpreting statutory grounds for review. Cited by the Court in discussing historical authorities; used only to show prior debates on the scope of review grounds.
Mohammad Azamat Azim Khan v. Raja Shatranji (AIR 1963 All 541 (FB)) Majority reason that a subsequent change in law is no ground for review unless it is retrospective; emphasises that the matter must exist at the time of the decree. Cited by the Court to support the conclusion that subsequent decisions are not, by themselves, grounds for review unless they show the law as it always stood at the time of judgment.
A.C. Estates v. Saraiuddin & Co. (AIR 1966 SC 935 at 939) Supreme Court approved Kotagiri principle: for discovery of "new and important matter", the matter must have existed at the time of the original order. Relied upon by the Court to reject the contention that every subsequent reversal constitutes an "error apparent on the face of the record."
Raia Shatrunjit v. Mohammed Azmat Azim Khan ((1971) 2 SCC 200 : AIR 1971 SC 1474) Affirmed the Full Bench of Allahabad; recognised that where a deeming provision shows the law to have existed from an earlier date, the error is apparent on the face of the record. Distinguished by the Court: it illustrates that retrospective statutory provisions may create grounds for review, but does not support review merely because of subsequent judicial decisions absent retrospective effect.
Shivdev Singh & Others v. State of Punjab & Others (AIR 1963 SC 1909) Authority that an order passed under Article 226 can be reviewed under the inherent powers of the Court. Accepted by the Court as a proposition of law but held that even under inherent powers no grounds were made out in the present case to exercise review.

Court's Reasoning and Analysis

The Court first isolated the surviving questions: whether the State is entitled to review the 1-1-1969 judgment and, if so, whether the grounds advanced justify review. The Government Pleader based the review application on (a) Order 47, Rule 1 CPC and (b) the Court's inherent powers. The State's central factual-legal contention was that subsequent decisions (notably the Supreme Court's 30-7-1969 pronouncement and the later Division Bench ruling of 15-10-1970) proclaimed the law as it had always been and thus operated with retrospective effect, rendering the earlier judgment erroneous on its face.

The Court examined authorities on whether a subsequent binding decision can constitute (i) the discovery of a "new and important matter", or (ii) an "error apparent on the face of the record", or (iii) "other sufficient cause" under Order 47, Rule 1 CPC. It reviewed older and later precedents (including the Privy Council's Kotagiri decision and subsequent Supreme Court and High Court authorities) and authoritative commentary (Mulla and AIR commentaries) which collectively support the proposition that review on the ground of a subsequent event or subsequent judicial decision is generally not permissible unless the matter existed at the time of the original order or the subsequent change in law is retrospective in operation.

The Court rejected the Government Pleader's argument equating a subsequent judicial decision with retrospective legislation. It explained that retrospective legislation, if effective from the time of the original judgment, can render the original judgment based on an incorrect statement of the law and thus give rise to an error apparent on the face of the record. By contrast, a subsequent judicial pronouncement ordinarily changes the law prospectively and does not, by itself, amount to a discovery of a matter that existed when the judgment was rendered.

The Court carefully distinguished decisions such as Pathrose and Chandrasekharan Nair (which treated subsequent decisions as grounds for review) and declined to accept them as correctly laying down the law for the present circumstances. The Court relied on Kotagiri, A.C. Estates, the Allahabad Full Bench (Mohammad Azamat Azim Khan), and Raia Shatrunjit to hold that a subsequent decision does not normally constitute a ground for review unless it establishes that the law was always the contrary of what was applied at the time of judgment (i.e., it has retroactive effect).

Turning to inherent powers, the Court acknowledged the authority that Article 226 orders can be reviewed under inherent jurisdiction (Shivdev Singh). Even so, the Court concluded that the present case did not disclose sufficient grounds to exercise inherent powers. It noted material facts in the 1-1-1969 judgment: no counter-affidavit had been filed by the Government and there was no appearance for the Government at the hearing. Further, the State had not taken steps to appeal the 1-1-1969 judgment and filed the review only on 18-8-1971. Given these circumstances and the lack of an identified ground falling within recognized review criteria, the Court found no basis to review the earlier order.

Holding and Implications

Holding: The Court DISMISSED the application for review of the judgment dated 1-1-1969. The dismissal was without costs.

Implications:

  • The State is not entitled, on the facts presented, to have the 1-1-1969 judgment reviewed on the ground that subsequent judicial decisions altered the law unless those subsequent decisions demonstrate that the law had retrospective effect to the time of the original judgment.
  • The Court did not finally decide whether Order 47, Rule 1 CPC is applicable to Article 226 proceedings in this case (it stated it need not venture a final opinion on that point), but held that even if Order 47 were applicable, none of its contemplated grounds for review were made out.
  • The Court affirmed that review under inherent powers is available in principle for orders under Article 226 (per Shivdev Singh), but emphasized that the inherent jurisdiction was not exercisable in the circumstances of this case because no sufficient grounds were shown.
  • No new legal principle or precedent was laid down; the decision applied existing authorities to deny review and left intact the earlier judgment in favour of the petitioner dated 1-1-1969.

Disposition

The application for review was dismissed. The dismissal was ordered without costs.

    Board Of Revenue And Another v. P.K Sved Akbar Sahib .

    The Judgment of the Court was delivered by

    Gopalan Nambiyar, J.:— On 1-1-1969, judgment was delivered by one of us in O.P No. 390 of 1567 allowing the petition and directing refund to the petitioner of a sum of Rs. 30,500/- collected from him as licence-fee for the years 1952 to 1957 under the Travancore Tobacco Act 1 of 1087 M.E The levy and Collection of Tobacco tax under the Act had been declared illegal by the Supreme Court in Abdulkhader's case (1962 Ker LJ 625) : (AIR 1962 SC 922) on the ground that the rules of 1950 and 1951 which authorised the levy and collection and which contained the charging provisions, had no independent existence after the implied repeal of the Tobacco Act by the Central Excises and Salt Act, 1944. Thereupon, the Kerala State Legislature passed the Validation Act 9 of 1964 (called Luxury Tax Act, for short) validating the levy and collection of the tax, as a tax on luxuries. The Validation Act was challenged in this Court. It was sustained by a learned Judge, in the first instance. On appeal, a Division Bench by Judgment in Writ Appeal No. 5070 of 1965 etc. dated 3-10-1966 held that it violated the provisions of Article 301 of the Constitution. On further appeal by the State to the Supreme Court, the decision of the Division Bench was set aside and the matter was remanded back to this Court, for fresh investigation before pronouncing whether the levy actually offends Article 301 or not. (vide the judgment of the Supreme Court dated 30-7-1969 reported in State of Kerala v. A.B Abdulkhadir (1969 Ker LT 649) : ((1969) 2 SCC 363 : AIR 1970 SC 1912)). After remand, a Division Bench of this Court sustained the validity of the Act by judgment rendered on 15-10-1970 reported in Abdulkhadir v. State of Kerala, 1971 Ker LJ 4 : (1971 Tax LR 512).

    2. This application for review of judgment was filed on 18-8-1971. It is based on the ground that the judgment of one of us D/- 1-1-1969 was on account of the invalidation of Act 9 of 1964 by the Division Bench ruling of this Court in Writ Appeal No. 5070 of 1965 etc. dated 3-10-1966 and as the same had been set aside on appeal by the Supreme Court, and the legislation itself had been sustained by the later Division Bench ruling dated 15-10-1970 the State is entitled to have the judgment reviewed. An application filed to excuse delay in preferring the petition for review has been allowed. The questions that therefore survive are whether the State is entitled to have the judgment reviewed; and if so whether there are adequate grounds to allow the application. The learned Government Pleader placed his case for review both under the provisions of Order 47, Rule 1 of the CPC and under the inherent powers of the Court. The provisions of Order 47, were invoked on the ground that S.A.L Naravan Row v. Ishwarlal Bhaewandas (AIR 1965 SC 1318 : 57 ITR 149) had ruled that proceedings relating to fax under Article 226 are ‘civil proceedings’, for the purposes of Article 133 of the Constitution, and this would attract Order 47. That the said provision would be attracted was expressly ruled in Chenchanna Naidu v. Praia Seva Transports Ltd. (AIR 1953 Mad 39) which was referred to and followed in Dilip Nath Sen v. Certificate Officer (AIR 1962 Cal 346), and again in Income-tax Officer. Masulipatnam v. K. Srinivasa Rao (AIR 1969 Andh Pra 441). The Calcutta decision refers to a judgment of Chagla, C.J in S.P Awate v. C.P Fernandes (AIR 1959 Bom 466). But the Bombay decision assumed that the Court had power to review its order passed on an application under Article 226, and stated that the same could be only on the ground of an error apparent on the face of the record which means that the error should be so clear and manifest that no court would allow it to remain on the record and not one to be demonstrated by a process of ratiocination. Our attention was called to the decision of a learned Judge of this Court (Raman Navar, J. as he then was) in Pathrose v. Kuttan alias Sankaran Nair, 1969 Ker LT 15 : (AIR 1969 Ker 186). There, the learned Judge held that a subsequent binding authority taking a different view of the law is a good ground for review. In the earlier part of the judgment the learned Judge appears to rest the conclusion both on the ground that it amounted to the discovery of “a new and important matter”, and in any case to an “error apparent on the face of the record”, within the meaning of Rule 1 of Order 47 of the CPC. In the course of the judgment the latter of these grounds alone appears to have figured prominently, and ultimately the learned Judge granted the review on that ground. The decision was followed by Krishna Iyer, J. in Chandrasekharan Nair v. Purushothaman Nair (1969 Ker LT 686). The learned Judge added:

    “Where it is a subsequent decision it is the discovery of a new and important matter, and where it is an antecedent decision, it is an error apparent on the face of the record.”

    3. One of us in State of Kerala v. Kesavan Vadhyan Namboodiri (1969 Ker LJ 450) held that a subsequent binding decision was not a ground for review under the inherent powers.

    4. Giving the matter our careful attention, we are unable to agree that, assuming Order 47, Rule 1 is applicable to the case, a subsequent binding decision in this case the pronouncement of the Supreme Court on 30-7-1969 and certainly of the Division Bench on 15-10-1970 would constitute either the discovery of “a new and important matter” or “an error apparent on the face of the record”. There is the early authority of a Division Bench of the Bombay High Court in Waghela Raisangii Shivsangji v. Shaik Masludin (1889) ILR 13 Bom 330 that a decision of the Privy Council reversing that of the High Court is “a new and important matter”, within the meaning of Secs. 623 and 624 of the Code of 1882. The authority of this decision has been shaken by the pronouncement of the Privy Council in Rajah Kotagiri Venkata Subbamma Rao v. Raiah Vellanki Venkatrama Rao (1900) 27 Ind App 197 : ILR 24 Mad 1 (PC). Lord Davey observed:

    “Section 623 enables any of the parties to apply for a review of any decree on the discovery of new and important matter and evidence, which was not within his knowledge, or could not be produced by him at the time the decree was passed, or on account of some mistake or error apparent on the face of the record or for any other sufficient reason. It is not necessary to decide in this case whether the latter words should be confined to reasons strictly ejusdem generis with those enumerated, as was held in Roy Meghrai v. Beeioy Govind Burral. (1) In the opinion of their Lordships, the ground of amendment must at any rate be something which existed at the date of the decree and the section does not authorise the review of a decree which was right when it was made on the ground of the happening of some subsequent event.”

    5. At page 1670 of Mulla's 13th Edition of the Code of Civil Procedure adverting to the Bombay decision, in Waghela Raisangji Shivsangji's case (1889) ILR 13 Bom 330), the learned author comments that the decision stands on the special facts of the case. At page 1672, the learned author observes that it is no ground for review that the judgment proceeds on an incorrect exposition of the law, or of a ruling which has subsequently been modified or reversed or that the law has been laid down differently in a later decision. Nor is a subsequent change in the law a ground for review unless it is retrospective in its operation.

    6. But it is claimed by the Government pleader that a subsequent binding decision proclaims and declares the law as it ever was, and therefore with retrospective effect, and that it stands on the same footing as a subsequent legislation with retrospective effect. This reasoning found favour with Raman Navar, J. in the decision in Pathrose's case (1969 KLT 15 : (AIR 1969 Ker 185)). We are unable to accept the reasoning as correct. In the case of a legislation Passed subsequently but with retrospective effect from the time when the decision sought to be reviewed was rendered, the position is that if the legislation is projected back to the date of the delivery of the judgment, there is, an error apparent on the face of the record in the judgment, based on the old or unamended legislation. On this aspect, we find ourselves in agreement with the reasoning of the majority in Mohammad Azamat Azim Khan v. Raja Shatranji (AIR 1963 All 541 (FB) See paragraphs 3 and 4). We are unable to agree, with the reasoning of Raman Nayar, J. distinguishing this case, in 1969 KLT 15 : (AIR 1969 Ker 186). In A.C Estates v. Saraiuddin & Co. (AIR 1966 SC 935 at 939). the Supreme Court approved of the Privy Council ruling in 27 Indian Appeals 197 and stated that for review on the ground of discovery of “new and important matter”, the said matter must exist at the time when the order sought to be reviewed was made. The decision of the Full Bench of the Allahabad High Court in AIR 1963 All 541 was affirmed by the Supreme Court in Raia Shatrunjit v. Mohammed Azmat Azim Khan ((1971) 2 SCC 200 : AIR 1971 SC 1474). After referring to the grounds for review, reference was made to Kotagiri case ((1900) 27 Ind App 197) and to the principle stated therein that review of a decree which was right when made, on the ground of some subsequent event was not contemplated. The Supreme Court observed:

    “Counsel for the appellant submitted that when the High Court decided the matter, the High Court applied the law as it stood and a subsequent change of law could not be a ground for review. The appellant's contention is not acceptable in the present case for two principal reasons first, it is not a subsequent law. It is the law which all along was there from 1952. The deeming provision is fully effective and operative as from 25 May, 1953, when the 1952 Act came into force. The result is that the Court is to apply the legal provision as it always stood. It would, therefore, be error on the face of the record. The error would be that the law that was applied was not the law which is applicable. Secondly. Section 4 of the 1952 Act confers power on the court to apply the law notwithstanding any provision contained in the Code of Civil Procedure. Therefore the application though entitled an application for review was not so. The substance and not the form of the application will be decisive.”

    7. In the AIR Commentaries, on the Constitution of India By Chitaley & Rao. Vol. III (2nd Edn) at pages 229 and 230, the conflict of judicial opinion on the question whether a decision in another case whether between the same or different parties, after the date of judgment sought to be reviewed, would be a sufficient ground for review, is noticed, and the learned authors submit that after the Privy Council decision in the Kotagiri case ((1900) 27 Ind App 197) the decision in (1889) ILR 13 Bom 330 and the cases following the same, cannot be accented as laying down the correct law. In the light of these, we are unable to accent the position that the subsequent decision of the Supreme Court rendered on 30-7-1969 or of the Division Bench given on 15-10-1970 constitutes discovery of “a new and important matter” justifying review.

    8. Nor can we regard these, as amounting to the discovery of a “mistake” or an “error apparent on the face of the record”. While we agree that the reversal or variance, or the overruling of a judicial decision by a subsequent one amounts to discovery of an error or a flaw in the reasoning of the decision reversed, varied or overruled, we are unable to hold that in every such case, there is an “error apparent on the face of the record”. The expressions underlined are quite strong, and have a well understood judicial connotation. Mere conflict or divergence of opinion cannot amount to an error apparent on the face of the record. This ground of review again, should therefore fail. It follows that in the light of the authorities discussed, we cannot accept the decisions in Pathrose's case (1969 KLT 15) : (AIR 1969 Ker 186), and in 1969 KLT 686 as laving down correct law.

    9. The only other ground for review under Order 47, Rule 1 is “other sufficient cause”. It is well settled that these words should be understood ejusdem generic with the two grounds immediately preceding them. Being so, it is enough for us to state that no other sufficient reason has been disclosed for review. The result is even if Order 47, Rule 1 of the CPC is applicable to the case, — as to which we need not venture a final opinion — none of the grounds contemplated by it are made out. The position is no better if the application is treated as one for review under the inherent powers of the Court. The decision of the Supreme Court in Shivdev Singh & Others v. State Of Punjab & Others (AIR 1963 SC 1909) is an authority for the Position that an order passed under Article 226 of the Constitution, can be reviewed under the inherent powers of the Court. But even so, no grounds have been made out for invocation of the inherent powers of review. The judgment sought to be reviewed, rendered on 1-1-1969 noticed that no counter-affidavit had been filed by the Government and there was no appearance for the Government at the hearing. Writ Appeal No. 5070 of 1965 and the batch of cases heard along with it, or at least some of them, were then pending in appeal before the Supreme Court. The Supreme Court set aside the Judgment of the Division Bench and remanded the matter back to this Court on 30th July, 1969. In pursuance of the remand, a Division Bench of this Court sustained the legislation by its judgment given on 18-10-1970. No steps were taken for an appeal against the judgment dated 1-1-1969. The application for review was filed only on 18-8-1971. In the circumstances, we see no ground to exercise our inherent Power of review. We dismiss this application but in the circumstances without costs.

    10. Application dismissed.

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    Board Of Revenue And Another v. P.K Sved Akbar Sahib .
    (Jun 8, 1973)