These Writ Petitions raise the question as to the availability of measure under S.26C of the Kerala General Sales Tax Act, 1963, hereinafter referred to as the "Act", to assessments relating to assessment years before the insertion of that provision into the Act as per the amending Act 23 of 1999 with effect from 1-4-1999.

2. The assessment order, which is the subject-matter of O.P.No.17877 of 2001 is for the assessment year 1995-96, the assessment orders which are the subject-matter of the other two Writ Petitions are for the assessment year 1996-97.

3. S.26C of the Act reads as follows:

"26C. Liability of Directors of a Private Company.-- Subject to the provisions of the Companies Act, 1956 (Central Act 1 of 1956) where any tax or other amount recoverable under this Act from any private company, whether existing or wound up or under liquidation, cannot be recovered for any reason whatsoever, every person who was a director of such company at any time during the period for which the tax or other amount is due under this Act shall he jointly and severally liable for the payment of such tax or other amount".

4. By the Amending Act 23 of 1999, S.26B was introduced making the