Judgment

BEG J.:- These are fifteen Civil Appeals arising out of petitions for writs of certiorari, prohibition, and mandamus against certain tax recovery proceedings instituted against their heirs and legal representatives of Thangal Kunj. Musaliar of Kerala who died on 19-2-1966. It appears that there were arrears of Income Tax due under the Travancore Income Tax Act (of 1121 ME) (hereinafter referred to as the Travancore Act ) and other enactments on income from the cashew nut export business. By an order passed on 10-6-1968, the Additional Personal Assistant of the District Collector Quilon, functioning as the Tax Recovery Officer, attached a number of immovable properties mentioned in a schedule to the order. He purported to act under Rule 48 in the second schedule to the Indian Income Tax Act of 1961, (hereinafter referred to as the 1961 Act ). He prohibited the appellants from transferring or otherwise dealing with properties in their possession on the basis of 22 certificates covering a total amount of Rupees 50,42,970.34 np. Some of the certificates were issued under Section 46, sub-section (2) of the Indian Income Tax Act of 1922 (hereinafter referred to as the 1922 Act