D. K. KAPUR, J. :- This is a petition under Articles 226 and 227 of the Constitution of India filed by the Union of India and others in respect of some orders passed under the Delhi Municipal Corporation Act, 1957 (hereinafter referred to as the Act), relating to Terminal Tax. The respondent M/s. Mahabir Pershad and Sons had imported some sanitary goods in July 1971. On Aug. 10, 1971 the Terminal Tax Officer noted that the statement of Shri Kunj Behari Lal, belonging to the first respondent firm, showed that there was a misdeclaration for the purpose of evading Terminal Tax and he imposed a penalty at the rate of ten times the tax. An appeal was taken by M/s. Mahabir Pershad and Sons to Shri M.K. Chawla, Additional District Judge, Delhi, under Section 169 read with Sections 178 to 183 and other sections of the Act. The appeal was rejected by order dated July 20, 1972. Thereafter a review application was filed which was decided by the learned Additional District Judge on Sept. 1, 1973. Therein it was noted that there was Rule 39 of the Terminal Tax Rules which applied to the particular case i.e., of wrong declaration. That Rule provided that on conviction a fine of Rs. 100/