Antony Dominic, J.

1. The petitioners in these writ petitions, the appellants in W.A.No.1995/12 and the party respondents in WA No.956/2013 were Directors of Private Limited Companies incorporated under the provisions of the Companies Act, 1956. Such companies were assessees under the KGST Act and were being assessed accordingly. By Section 3 of the Kerala Finance Act 1999, (Act 23 of 1999) , Section 26C was introduced to the Kerala General Sales Tax Act with effect from 01.04.1999. This Section reads thus: 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 be jointly and severally liable for the payment of such tax or other amount.

2. Relying on the provisions of Section 26C, revenue recovery proceedings were initiated against the petitioners in the writ petitions, the appellant in