Judgment

CHANDRACHUD, J. :- In 1959, the Orissa Legislature enacted the Orissa Taxation (on Goods Carried by Roads or Inland Waterways) Act, 7 of 1959, the constitutionality of which was challenged by the appellants on the ground that the Bill leading to the Act was moved without the previous sanction of the President of India, as required by the Proviso to Art. 304 of the Constitution. During the pendency of the writ petitions filed by the appellants in the Orissa High Court, the Orissa Legislature passed the Orissa Taxation (on Goods Carried by Roads or Inland Waterways) Validation Act, 18 of 1962, validating the Act of 1959. The High Court accepted the appellants contention that the Act of 1959 was unconstitutional but it dismissed the writ petitions on the ground that the appellants were not entitled to any relief as they had not challenged the Act of 1962 which had validated the Act of 1959. After the decision of the high Court, respondent No. 2, the Tax Officer, assessed tax in varying amounts for different quarters on the goods carried by the appellants by road. The appellants then filed fresh writ petitions under Art. 226 of the Constitution challenging the Act of 1962. Thos