The petitioner in these two petitions under Art.226 of the Constitution is the Food Corporation of India. It challenges the levy of property tax/building tax under the Kerala Municipalities Act, 1960 (Act 14 of 1961) and the Kerala Panchayats Act 32 of 1960 on buildings belonging to it. I shall state the facts in O.P.No. 5346 of 1992 which relates to the buildings belonging to the petitioner in the Angamaly Municipality, the facts in the other cases being similar, the only difference being that the buildings are in Thikkodi Panchayat governed by the Kerala Panchayats Act.

2. The petitioner which is a body corporate established under the Food Corporations Act, 37 of 1964, has constructed buildings for its purposes within the limits of the Angamaly Municipality. It is not in dispute that the buildings and the land on which they stand, belong to the petitioner. The petitioner had paid the property tax due to the Municipality up to and inclusive of the year 1990-91 without demur, but when demand was raised for the tax for the year 1991-92 as per Ext. P4 series of notices, petitioner objected, and after an appeal to the Municipal Council was rejected for non-compliance with t