M. Sathyanarayanan, J.

The appellants are the official respondents in writ petitions. The writ petitions were filed by each of the respondent in these writ appeals, challenging the demand of additional stamp duty on the document of sale executed by the Tamil Nadu Police Housing Corporation Limited ( in short " Corporation") a Government of Tamil Nadu Undertaking, in favour of the writ petitioners and consequential refusal to release the respective sale deeds to the writ petitioners, already registered by the Office of the Sub Registrar of Assurance, on account of non payment of additional stamp duty.

.2. The Tamil Nadu Police Housing Corporation is a Government of Tamil Nadu Undertaking which has been formed to provide houses, police stations and office for police personnel. Each of the writ petitioner was allotted a flat by the Corporation. The respective writ petitioner had executed lease-cum-sale agreement in the year 1985 and also paid instalments in full. Thereafter, sale deed was given to each of the writ petitioner and the sale deeds were registered in the Office of the Sub Registrar at Thiruverumbur, Trichy District.

3. The third appellant herein all of a sudden, during the beginning of the year 2000, started issuing notices demanding additional stamp duty on the instruments purporting to exercise powers under Section 47-A of the Indian Stamp Act. The reason for demand of additional stamp duty was that market value of the property as on the date of the registration has not been taken into consideration by the Sub Registrar, Thiruverumbur while registering the sale deeds.

4. The writ petitioners formed an association viz., Trichy Navalpatti Police Colony Owners and Occupants Association and they submitted representation to the third appellant herein stating that the power under Section 47-A of the Stamp Act can only be exercised by the Registering Officer when he has reason to believe that the market value of the property which is the subject matter of conveyance, has not been truly set forth with a view to fraudulently evade payment of stamp duty and that mere lapse of time between the date of agreement and the execution of document will not be the determining factor that the document is under value. The third appellant in turn had sent a communication dated 20.12.2000 to the second appellant herein stating that all the sale deeds given by Tamil Nadu Police Housing Corporation in favour of the allottees/writ petitioners may be registered on the basis of the real value of the property agreed between the said Corporation and the allottees.

5. The second appellant in spite of such communication from the third appellant, had rejected the request of the above said association on 21. 2001. The association preferred further appeal to the first appellant who was also rejected the said appeal vide order dated 11. 2001. The association, challenging the vires of the said order, filed W.P.No.11082 of 2001 and this Court has passed an order dated 4. 2002 stating that since the issue pertaining to the right of an individual, each individual has to file a separate writ petition setting out the details and granted liberty to the association to file a writ petition by each individual. Hence the writ petitions came to be filed.

.6. In the writ petitions, it is contended that the transaction of sale between the Corporation and the respective writ petitioner was a sale between the Government of Tamil Nadu Undertaking and the allottee and there cannot be any under valuation or mala fide attached to such transactions. It is further contended that unless there is fraudulent evasion in payment of stamp duty, aid of Section 47-A of the Indian Stamp Act cannot be pressed into service to review the payment of stamp duty already paid on documents.

7. The second appellant who was arrayed as second respondent in the writ petitions filed his counter submitting that the Corporation has built various types of houses and allotted to