Ramaprasada Rao, J.-The question referred to us by the Chief Controlling Revenue Authority, Board of Revenue, Madras - 5 is as follows:

“Whether in the circumstances and facts of the case the document, dated 30th June, 1963 (Document No. P. 37 of 1973 of the District Registrar’s Office, Nagercoil) executed by V. Daniel in favour of” The Society of Trustees of Indigenous Churches in India “ represented of Brother Bakht Singh Chabra styled as a” release deed “ should be termed as ‘a conveyance’ as defined under section 2 (10) of the Act attracting stamp duty under Article 23 of Schedule I of the Stamp Act.”

2. By way of prefatory remarks, we make it clear that if the instrument in question which we are asked to interpret is to be understood as a conveyance, then it is not properly stamped, but if it is a release deed as it is styled and understood by the parties, then it has been so properly stamped.

3. For the purpose of establishing a church and incidentally to acquire properties, both movable and immovable for the benefit of the said church, moneys belonging to a religious institution called the Society of Trustees, which at that time was not registered and which was not formed as a

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