Judgment

GROVER, J.:- These appeals have been brought by special leave from a judgment of the Andhra Pradesh High Court.

2. Three suits, namely, O. S. Nos. 222, 223 and 466 of 1960 were filed in the Guntur court in which the relief claimed was for a declaration that the general revision of the rental values of the houses and buildings effected by the Guntur Municipality in the year 1960 for the purpose of assessment of tax was ultra vires and illegal and for a consequential relief of a permanent injunction restraining the municipality from acting on the special notices issued to the tax payers.

3. Section 81 of the Madras District Municipalities Act 1920, hereinafter called the Municipalities Act" gives the description and classes of property tax and other taxes leviable by the municipality. Section 82 gives the method of assessment. It is provided by sub-s. (2) of that section that the annual value of lands and buildings shall be deemed to be the gross annual rent at which they may reasonably be expected to let from month to month or from year to year less certain deductions. The District Munsif by a common judgment delivered in the three suits held that the annual value had to be