Mockett, J.

1. This is a civil revision petition to revise an order of the learned District Munsif, Tinnevelly and it relates to the Stamp Act. The defendant made a promissory note in Colombo on the 11th March, 1934 in favour of one Arunachala Thevar. The promissory note was at the time stamped with one anna adhesive stamp, the correct stamp for a note in British India and was duly cancelled. That must be taken to have happened on the 11th March, 1934. On or before the 11th March, 1935, the promissory note came into British India and was assigned to the plaintiff. The relevant portions of the Stamp Act are:

Section 3. Subject to the provisions of this Act and the exemptions contained in Schedule I, the following instruments shall be chargeable with duty of the amount indicated in that schedule as the proper duty therefore respectively, that is to say--

(b) every promissory note drawn or made out of British India on or after that day and accepted or paid, or presented for acceptance or payment, or indorsed, transferred or otherwise negotiated, in British India.

2. Section 19 provides that:

The first holder in British India of any promissory note drawn or made out of British India