RAJAMANNAR, C.J.

This is a petition under article 226 of the Constitution for the issue of a direction in the nature of a writ of mandamus to the Income-tax Officer, Second Additional City Circle, Madras, the Collector of Nilgiris, Nilgiris District, and the Tahsildar of Coonoor, Coonoor Taluk, Nilgiris District, restraining them from proceeding to attach, or to bring to sale, the petitioner's properties for the realisation of the alleged income-tax arrears of her husband, Taranisingh Gramani, and in particular from proceeding with the sale of the Benhutty Estate, Kulikal Village, Coonoor Taluk, Nilgiris District.

For the recovery of arrears of income-tax due from the petitioner's husband, Tharansingh Gramani, a certificate was issued by the Income-tax Officer, the first respondent, to the Collector of Nilgiris (the second respondent) under section 46 (2) of the Indian Income-tax Act. The Collector, in pursuance of this certificate, proceeded under section 27 of the Madras REvenue Recovery Act to attach the property described as Benhutty Estate for the realisation of the said arrears. This estate, it is common ground, was purchased in the name of the petitioner by a deed