The 3rd respondent is a dealer registered under the Kerala General Sales Tax Act (for short the Act). The appellant is a surety to the 3rd respondent and he executed Ext.P3 bond as directed by the sales tax authorities under rule 6 of the Kerala General Sales Tax Rules (the Rules for short). Ext.P3 shows that the liability of the surety is to a tune of Rs.1 lakh. A sum of more than Rs.23 lakhs is due from the 3rd respondent as sales tax arrears. Revenue recovery proceedings were initiated against the appellant as well.

2. The writ petition was filed by the appellant herein praying for the following relief’s:

“i. issue a writ of certiorari or other appropriate writ, direction or order calling for the records leading to Exhibit P5 demand notice and quashing the same;

ii. issue a writ of mandamus or other appropriate writ, direction or order directing the1st and 2nd respondents to abstain from enforcing any demand against the petitioner beyond one half of the tax assessed on the 3rd respondent for the relevant year of registration certified in Ext.P2 or the sum assured in Ext.P3, whichever is less;

iii) pronounce that the assessing authority has to issue demand notice to the