MOHAMMED, J.: - The dispute in these writ petitions is between the Alleppey Municipality, Corporation of Calicut and Corporation of Cochin (hereinafter together called 'Municipal Corporations' as the context may require) on the one hand and the Food Corporation of India (for short 'FCI') on the other. The central theme of the context relates to the levy of property taxes and service charges by the 'Municipal Corporations' under provisions of the Kerala Municipal Corporations Act, 1961 and the Kerala Municipaliaties Act, 1960 and the claim of exemption by the 'FCI' under Art.285(1) of the Constitution of India.

2. The relevant facts involved in these cases are summarised here as below: O.P. No. 4653 of 1987 was filed by the FCI, Alleppey for a declaration that it is not liable to be assessed to any property tax or service charge under the provisions of the Kerala Municipalities Act, 1960. It also prayed for quashing Exts.P12(a), (b), (c), to (t), P13, P14, P16 and P17 bills and communications issued by the Alleppey Municipality levying service charges in respect of the building owned by it. In the regular course the Alleppey Municipality has made proposal to levy a sum of Rs. 56,954.70 towards the property tax for the years 1968- 1969, 1969-1970, 1970-1971, 1971-1972 and 1972-1973 (first half). The said proposal was resisted by the FCI on the ground that it is not liable to pay the said tax in view of Art.285(1) of the Constitution. In spite of this objection. Alleppey Municipality issued demand notices for the subsequent years and therefore FCI filed suit. O.S. No. 301 of 1976 before the Munsiff's Court. Alleppey for an injunction restraining the first defendant - Alleppey Municipality from recoverning any property tax by coercive processes or otherwise. The said suit was ultimately dismissed by the trial Court but in appeal, the Subordiante Judge's Court, Alleppey, by the Judgment dated 20-12-1980 in A.S. No. 41 of 1978 decreed the suit on the ground that the land and buildings belong to the Union of India. Though a Second Appeal was filed before this Court as S.A. No. 667 of 1982, it was dismissed by a learned single Judge as per judgment dated 19-11-1982. Thus decree for injunction passed by the Subordinate Judge's Court Alleppey was confirmed. Thereafter the FCI made a demand for refund of the tax already collected. The Municipality took the stand that "the amount would be refunded after deducting therefrom the service charges. Subsequently the Municipality as per Exts.P8(a) and P8(b) intimated the petitioner that it is liable to pay an amount of Rs. 87,178.50 towards service charges for the period 1968-1969 to 1972-1973 (first half) calculated at the rate of Rs. 19,373.00 per year and that after giving credit to Rs. 56,954.70 being the property tax already collected for the aforesaid period, the petitioner is liable to pay a further amount of Rs. 30,223.80. The FCI filed objections contending that no amount was recoverable from it and commutation of service tax was illegal. After considering the objections filed by the FCI the Municipality ultimately issued Ext.P12(a) and P12(b) demanding a sum of Rupees 1,31,080.80 after giving credit to Rupees 56,954.70 refundable to it. Exts. P13 and P14 are the bills issued by the Municipality demanding service charges for the year 1986-1987 (first and second half). As against these bills FCI filed revision petition as per Ext.P15(a). The said revision appears to have been rejected by the Municipality as per Ext.P16. Subsequently the Municipality issued Ext.P17 notice to the FCI demanding to pay the arrears of service charges for the aforesaid years. Thereafter the Municipality has issued 18 bills (Exts.P12(c) to P12(t) for the period 1968-1969 to 1985-1986 (first half) under Rule 5(1) of Schedule II of the Municipalities Act. It was in that background FCI has filed this writ petition challenging the bills and notices referred to above.

3. In O.P. No. 5356 of 1992 filed against