C.N. Ramachandran Nair, J.

1. Petitioner, a registered Cooperative Society under the control of the Government purchased immovable property from another Cooperative Society by name Palakkad Wholesale Cooperative Consumer Stores Ltd., which was under liquidation. The purchase was in public auction conducted by the Liquidator which was confirmed by High Court by it's orders dated 20/01/1998. Since Ext. P1 Government Order grants exemption from stamp duty, for documents including inter Cooperative Societies sale deeds, sale deed in white paper was presented for registration. The Sub Registrar, however, expressed doubt about the eligibility for exemption from stamp duty under the Kerala Stamp Act, 1959 based on the above notification, and therefore he impounded the document and forwarded the same to the District Registrar, Palakkad under S.33(1) of the Stamp Act for adjudication. Since the District Registrar acting in exercise of power under Ss.31 and 39 of the Stamp Act himself felt doubt about the chargeability of the instrument, he referred the matter for opinion of the Government under S.54(2) of the Act. Pursuant to reference the Government heard the petitioner and held tha