KAN SINGH, J.—Petitioner Shri Nathulal Fatehpuria has moved this writ application under Article 226 of the Constitution questioning legality of seizure of his account books and goods from his shop on 19-9-66 and has prayed for an appropriate writ, direction or order against the respondents. The case set up by the petitioner in his writ petition is briefly this.

2. Petitioner is carrying on the business of selling and supplying cloth, Saris, both plain and embroidered garments with Salma, or gota work done on them and other ready-made garments. The petitioner is registered as a dealer under the Rajasthan Sales Tax Act, 1964, hereinafter to be referred as the Act. He proceeds to say that he maintains regular books of accounts and has been paying the sales-tax regularly. On 19-9-66 a party of officers numbering about 30, consisting of respondent No. 3, Shri Surendra Sharma, Special Officer, Anti-Evasion, Commercial Taxes Department, Jaipur and others came to his shop at about 4.00 p.m. According to the petitioner, this party had a pre-planned policy of collecting Government revenue by fair or foul means, and in pursuance thereof first of all those officers enquired from him whether he was paying sales-tax on Saris embroidered with Gota Salma and Sitara, but when the petitioner replied that these goods were exempt from sales tax by virtue of Government Notification No. F.(99) EAT/-60 dt. 26-3-62, the respondents refused to accept this reply and demanded from him rs. 2,000/- as composition money for the offence of evasion of Tax. The petitioner, however, did not accede to this demand and, therefore, the party of the Government officers asked the customers at the shop to go away and they put a guard around the shop and the entire record of the petitioner consisting of account books and other papers was ordered to be seized. Accordingly, the party of officers seized the record of the petitioner. Thereafter certain lists were prepared by the respondent No. 3, and the petitioner was furnished with the list regarding seizure of the account books. After serving him with a notice Ex. P/5, the officers are further alleged to have seized the goods lying at the petitioners shop such as, Saris, ready-made garments, both ordinary and those on which there was embroi-dary work of Salma, Sitara and Gota. It is the petitioners case that thereafter he was served with notices Ex. P/7, and was told that as the clothes found at his shop were not entered in his account books he should pay four-times the tax recoverable from him, failing which the goods would be confiscated in accordance with sec. 22(6) of the Act. The petitioner felt aggrieved of this action of respondent No. 3 and his party and, therefore, he proceeds to say that he gave a telegraphic notice to respondent No. 3 to return the books and other papers seized from him as also the goods that were confiscated. As the respondents failed to give any relief to the petitioner he has come to this court. He has contended that the action of the officers was illegal for two reasons: (1) that the provisions of sec. 22(3) (4) were violative of Articles 14, (19)(l)(f) and (g) of the Constitution and, the officers could not have taken any action under the aforesaid provisions and(2) that there was non-compliance of the provisions of sec. 22(3) of the Act inasumch as in the notice Ex. P/5, respondent No. 3 had not mentioned any reason for his suspicion that the petitioner was attempting to evade sales-tax under the Act and secondly no reasons have been recorded in writing for the seizure of the account books or the stock of garments and Saries lying at the petitioners shop.

3. The writ petition has been opposed by the State of Rajasthan and other respondents. It is denied by them that the seizure of the account books or the goods was illegal on any of the grounds mentioned by the petitioner. It is submitted on their behalf that in the opening words of E. P/5 it had been mentioned that it was on the basis o

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