Though the facts pleaded in these two cases are different, the issues raised for consideration are common. Therefore these cases were heard together and are disposed of by this common judgment.

2. I shall now refer to the facts in these two cases separately.

3. In so far as WP(C) No. 21475/09 is concerned, petitioner's father was the partner of a firm by name Malabar Wires and Allied Products. In 1990, he conveyed the property comprised in RS No.338/7 of Thiruvalloor Desom to his wife by document Nos.507/90 and 533/90. Subsequently, on 6/5/93, his father expired.

4. Long thereafter, assessments under the KGST Act for the assessment years 1986-87 to 1992-93 were completed as per Ext.P14 series of orders issued on 25/11/96. Subsequently, by Exts.P1(a) and P1(b) notices dated 30/7/2002, revenue recovery was initiated against the property conveyed to the petitioner's other, to recover the tax dues of the firm. Petitioner's mother challenged these notices by filing OP No.22822/02. That O.P was disposed of by Ext.P2 judgment holding that the department is free to proceed against the firm and its partners and against the assets of the partners for recovery of the tax. It was also held that if the respondents have a case that the petitioner's husband had transferred property to the petitioner to evade tax, then of course, the respondents are free to adjudicate the matter by attaching the said property.

5. Respondents continued the revenue recovery action by issuing Ext.P3 notice under Section 49 of the Revenue Recovery Act. Thereupon, petitioner's mother again filed OP No.9562/03 which was disposed of leaving it open to her to file a claim petition before the revenue recovery authorities. Accordingly, she filed a claim petition which was rejected by Ext.P4 order of the Tahsildar. Against Ext.P4 order, petitioner's mother filed appeal to the District Collector, which was also rejected by Ext.P5 order. While the revision filed by the petitioner's mother against Exts.P4 and P5 orders were pending before the Land Revenue Commissioner, revenue recovery proceedings were again initiated. Thereupon, petitioner's mother filed WP(C) No. 23723/06 and that writ petition was disposed of by Ext.P6 judgment directing disposal of the revision, which was pending before the Land Revenue Commissioner and to keep further recovery action in abeyance.

6. The revision was accordingly considered and the Land Revenue Commissioner passed Ext.P7 order rejecting the revision. Immediately thereafter, the revenue recovery proceedings were revived and therefore the petitioner's mother once again approached this court by filing WP(C) No. 25044/07. By Ext.P8 judgment rendered on 18th of December, 2007, the writ petition was disposed of directing the Land Revenue Commissioner to reconsider the revision and staying recovery pursuant to the assessment orders. The revision was accordingly reconsidered and was rejected by Ext.P9 order. In the meantime, his mother expired and therefore the petitioner filed Ext.P10, a further revision, before the Government of Kerala invoking its powers under Section 83(2) of the Revenue Recovery Act.

7. During the pendency of this revision, by Ext.P11, revenue recovery proceedings were again revived and that provoked the petitioner to file WP(C) No. 23893/2008. The writ petition was disposed of by Ext.P12 judgment directing consideration of Ext.P10 revision. Accordingly, the revision was considered and was rejected by the Government as per Ext.P13. It is in these circumstances, WP(C) No. 21475/09 is filed.

8. As far as WP(C) No. 22859/09 is concerned, by Ext.P1sale deed bearing No.1983/1992 of SRO, Perinthalmanna dated 20/7/92, petitioner herein purchased 35 cents of land and a building comprised in RS No.21/8 of Angadipuram Village. After the property was purchased, Ext.P2 notice of sale of immovable property under Section 49(2) of the Revenue Recovery Act was issued by the respondents proposing to sell the property for realising the s