Honble NAOLEKAR, J.–Facts in brief, necessary, for disposal of this writ petition are:

(2). Gyan Chand the petitioner and one Laxman Singh jointly purchased plots situated at Bhilwara by sale-deeds dated 12.3.1984 & 14.3.1984. Laxman Singh who was the joint owner of the said two plots released his shares in respect of both the plots by a deed dated 17.7.1985 titled as `Release Deed. The documents were presented for registration before the Sub- Registrar, Bhilwara. The matter was taken up under Sec. 47C(3) of the Raj. Stamps Law (Adaption) Act, 1952 by the Deputy Inspector General of Stamps ex-officio, Collector Stamps, Ajmer and the document was held to be a deed of conveyance and not `Release Deed. The petitiooner was directed to pay the additional stamp duty of Rs. 39022.75 including penalty etc.

(3). Aggrieved by the said order, the petitioner preferred a revision petition under Section 56 of the Indian Stamp Act before the Board of Revenue. The revision petition and, thereafter, review application, filed by the petitioner were dismissed.

(4). Submission of the learned counsel for the petitioner is that the property having been purchased by the petitioner and Laxman Singh, jointly

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