( 1 ) ). BY this petition under Clause 15 of the Letters Patent, challenge, at the instance of the appellant-original petitioner, is against the order passed in Tax Appeal No. 17 of 1998 by the Director of Transport, Gujarat state which came to be confirmed in. Special Civil Application No. 9282 of 1998, by the Learned single Judge on 31-8-2000, on the main premise that, the appellant cannot be fastened with liability for payment of arrears of Motor vehicles Tax as he had sold the vehicle.

( 2 ) IN order to appreciate the merits of this appeal and challenge against it, a few relevant material facts may be highlighted, here as under :- 1. The appellant-original petitioner is doing a business of Travel Agent, at anand. The petitioner is the owner of some luxury buses. 2. Out of them, one luxury bus bearing No. GTG-4444 had already been sold to the respondent No. 3, one Mr. D. N. Patel, as per the case of the original petitioner, and therefore, the petitioner is not liable for the payment of arrears of tax in respect of the said vehicle. 3. The said vehicle was also transferred by the respondent No. 3 Mr. D. N. Patel to respondent No. 4 one Mr. R. N. Patel. 4. The respo