Rajamannar, C.J.,-The question referred to us by the Board of Revenue under section 57 of the Stamp Act is whether the document styled a deed of release executed on 23rd May, 1949, is liable to be charged with stamp duty under Article 39(b), 44(b) and 19 of Schedule 1-A of the Stamp Act respectively.

The Referring Authority was of the opinion that the document in question came under all the three articles and therefore liable to be charged with stamp duty under each of these three articles. Article 39(b) of Schedule 1-A of the Act deals with an instrument of dissolution of partnership Article 44(b) is an article applicable to an instrument of release whereby a person renounces a claim upon another person or against any specified property. Article 19 applies to a conveyance.

The executants of the deed are three persons, who along with two persons in whose favour the deed was executed, were partners of a registered firm known as “Gudiyatham Lungi Company.” The executants appear to have ceased to be partners of the firm from and after 12th April, 1949. The preamble recites that the releasors, i.e., the executants were co-owners of the immovable property described in the schedule to the

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