P.N.BHAGWATI, J.

(1) THIS appeal by special leave raises two questions relating to the interpretation of certain provisions of the Bombay Municipal Boroughs Act, 1925. The facts giving rise to the appeal are few and may be briefly stated as follows.

(2) THE respondents are ratepayers liable to pay property tax in respect of their lands and buildings situate within the limits of the erstwhile Municipal Borough of Dharwar now converted into the Hubli Dharwar Municipal Corporation. The Municipal Borough of Dharwar (hereinafter referred to as the municipal borough) was at the material time governed by the provisions of the Bombay Municipal Boroughs Act, 1925 (hereinafter referred to as the Act). The Chief Officer of the municipal borough prepared an assessment list for the official year 1951-52 containing revised valuation and assessment of the lands and buildings situated within the limits of the municipal borough and published it on 1/05/1951 in accordance with the provisions of the Act. The respondents and several other ratepayers filed their objections against the valuation and assessment in the assessment list and consequently on the decisions on the