( 1 ) THIS is a reference under S. 54 (1) of the Mysore Stamp Act, 1957 by the Chief Controlling Revenue Authority in Mysore. The opinion sought by the Chief Controllingg Revenue Authority is as to whether the document in question dt. 4th April, 1967 described as a release deed is a conveyance on sale chargeable to stamp duty under Art. 20 of the Schedule to the Act, or as to whether the document is a release deed chargeable to stamp duty under Art. 45 of the Schedule to the Act.

( 2 ) THE document in question which is described as a release deed was executed by one Mr. J. N. A. Hobbs in his capacity as Attorney of one Mr. Robert Ormsby Oliver son of Godfrey Ryder Oliver in favour of the respondent Sri M. L. Manjunatha Setty. It is clear from the schedule to the said document that it relates to an estate known as 'sambercool estate' in Attigere village in Chikmagalur District. The document is written on a stamp paper of the value of Rs. 22-50 np. The document was presented for registration before the Sub Registrar of Chikmagalur on 21st July, 1967. The Sub-Registrar impounded the document on the ground that the document is not adequately stamped and forwarded the same