RATNAM J.

These writ petitions praying for the issue of writs of prohibition at the instance of the Coimbatore Club (hereinafter referred to as "the club") challenge the legality and validity of the notice issued by the WTO, City Circle 1(2), Coimbatore, the respondent herein, to the club under s. 16(2) of the W.T. Act, 1957 (hereinafter referred to as "the Act"), for the assessment years 1972-73 to 1976-77. Earlier, notices under s. 17 of the Act, had been issued to the club on the ground that for the assessment years mentioned above, the assessable net wealth of the club had escaped assessment and the club was called upon to deliver returns of its net wealth for the years in question chargeable to tax together with other particulars. The club sent a reply stating that on the abolition of wealth-tax on companies from the assessment year 1960-61 onwards, wealth-tax is chargeable only on individuals and HUFs and as the club did not fall within these categories of assessable units or entities, it is not liable to be assessed to wealth-tax. The club also put forward the objection that it could not be included within the expression "individual" occurring in s. 3 of the Act as it had been assessed for purposes of income-tax as an association of persons and the property of the club was also not held by a body of individuals. In these proceedings, the club seeks to have the notices quashed on the ground that it is not a taxable unit or entity under s. 3 of the Act and all the notices issued are, therefore, without jurisdiction In the common counter filed by the respondent, the issue of notices under the Act is sought to be supported on the basis that the club should be regarded as an "individual" for purposes of the Act, as the expression "individual" is not confined only to a human being, but is wide enough to take in a group of persons forming a single collective unit or entity and owning property. Alternatively, it was claimed that even on the footing that the club can be treated as an association of persons, such an entity or unit is also comprehended within the expression "individual", notwithstanding that s. 3 of the Act does not specifically mention association of persons as such. As objection was also raised that having regard to the availability to the club of other adequate alternative remedies under the Act, the discretionary remedy of writ should not be grantedThe principal and the only contention urged by the learned counsel for the petitioner is that a body like the club as in this case cannot be included within the ambit of the expression "individual" in s. 3 of the Act as an assessable unit or entity and the proceedings commenced by the respondent herein by way of issue of notices calling upon the club to submit a return of its wealth and also other particulars are, therefore, without jurisdiction. Strong reliance in support of this contention was placed by the learned counsel for the petitioner on the decisions in Orient Club v. WTO, Orient Club v. CWT and Willingdon Sports Club v. C. B. Patil, Addl. WTO. On the contrary, the learned counsel for the Revenue submitted that though in s. 3 of the Act, the expression used is "individual", yet it is wide enough to comprehend within its scope not only human beings individually, but also a group or body of human beings or other persons forming a single collective entity compendiously known as a club, a statutory corporation, etc., and, therefore, the charging s. 3 of the Act cannot be confined to an "individual" in the sense of a human being only. The further submission of the learned counsel was that the expression "individual" was of sufficient width and amplitude to take within its fold a plurality of individuals or a body of individuals banded together as a single collective entity by ties of common aim or joint interest other than the acquisition of gain and having rights in relation to common property which can be regarded as an entity or unit by itself for