CHANDRA REDDY, J. : -

These two appeals are against the judgment of the Subordinate Judge, Kurnool, in O. S. Nos. 52 of 1950 and 54 of 1949. The two suits giving rise to these appeals were instituted by the same plaintiffs for the purpose of setting aside some sales. As the subject-matter of the suits was practically the same and the plaintiffs were the same they were tried together and a common judgment was delivered.

2. In O. S. No. 52 of 1950 the 1st defendant is the Union of India, defendants 2, 3 and 4 the District Collector, Kurnool, Revenue Divisional Officer, Nandyal and the Tahsildar, Nandyal, respectively. The other defendants are the purchasers of various items of property in auction held by the revenue authorities. The suit was brought for a declaration that the assessment orders made by the Income-tax Officer, Kurnool, in G. I. No. 3810/44-45, 45-46 and 46-47 are unenforceable against the suit properties of the plaintiffs and consequently the sales of those properties by the revenue authorities were void and illegal and for other consequential reliefs.

3-4. The circumstances leading up to this suit are the following : -

The plaintiffs, three in number, and their