This writ petition has been filed by petitioner Smt. Nirmal Malik against order dated 17-8-1998 of the Collector (Stamps) Ajmer in case No. 564/1998, whereby the Collector (Stamps), Ajmer, accepted reference made by Sub Registrar, Ajmer, and held that the document of transfer deed in favour of petitioner involved transfer of physical possession and exchange of rights and came within definition of conveyance, and held the value of the lease to be Rs. 2,25,01,500/- and found stamp duty of Rs. 22,50,150/-, registration fee of Rs. 25,000/- and penalty of Rs. 1,00,000/- payable by petitioner and after deducting already paid stamp duty and registration fee by petitioner, a sum of Rs. 22,46,800/- was found due to be paid by petitioner towards stamps duty, Rs. 24,665/- towards registration fee and penalty of Rs. 1,00,000/-; thus, a total sum of Rs. 23,71,465/- was found recoverable from petitioner.

2. Briefly stated facts of the case are that a mining lease for minerals i.e. mica, feldspar and quartz near village Nareli, Tehsil and District Ajmer for an area of 45.58 hectares was granted by mining department of the Government of Rajasthan in favour of one Arvind Kumar Garg, proprieto