1. These writ petitions are filed by schools affiliated to the CBSE and they say that they are entitled to be exempted from the levy of property tax payable under the provision of Section 235 of the Kerala Municipality Act, 1994. Section 235(d) as it originally stood provided that the buildings recognised by Government or registered with the Municipality and owned and occupied by educational institutions and used for teaching are exempted from property tax. However, Section 235 was substituted by Act 30 of 2009 w.e.f. 7/10/2009 and the substituted section 235(b) reads thus:

"235. Exemption from property tax, service cess etc-The following buildings and lands shall be exempted from the property tax as may be levied under section 233 and service cess as may be levied under sub-section (4) of section 230, namely:-

(a) .............

(b) buildings exclusively used for educational purposes or allied purposes under the ownership of educational institutions owned by the Government, aided or functioning with the financial assistance of the Government and the hostel buildings wherein the students of the said institutions reside."

2. Nobody has a case that the petitioners are educa