( 1 ) THE appellant was the owner of truck bearing No. GTD 5177. He sold the said truck to Himatlal Jaysukhlal-original defendant No. 3 on 1-10-1975. On payment of price delivery of the truck was given to Himatlal on that day. A sale deed in that behalf was also executed. It was agreed by the parties that motor vehicle taxes on and from 1-10-1975 were to be paid by the purchaser. The applicant had also informed the registering authority about this transfer by its letter dated 3-10-1975 and had also sent a copy of the sale deed alongwith it. The appellant however received a notice in 1982 calling upon it to pay the motor vehicle tax and penalty for the period from 1-10-1975 to 31-12-1981. The appellant pointed out to the registering authority that it had already transferred the truck in 1975 but the registering authority did not accept this plea of the appellant on the ground that the appellant has not ceased to be a registered owner of the truck and therefore it has continued to remain liable to pay the tax. As the tax demanded by the registering authority was not paid by he appellant the registering authority tried to recover the said amount as arrears of land re