Kunhi Raman, J.

1. An interesting question of law is raised in this second appeal to appreciate which the facts must be briefly stated. The South Indian Railway Co. Ltd., who are the appellants own properties at Mandapam. These were situated within the territorial limits of a local authority which until 1930 was known as the Pamban Union and for some time subsequently as the Pamban Panchayat Board. This Board comprised the revenue" villages of Pamban and Mandapam. By a notification published by the Madras Government in accordance with law on the 6th September, 1935, the revenue village of Pamban was excluded from the limits of this local body which was renamed Mandapam Panchayat Board. In effect there was then a bifurcation of what used to be known as the Pamban Panchayat Board into the Mandapam Panchayat Board and the Pamban Panchayat Board. There is no doubt that the properties owned by the appellant Railway Company and with which the present case is concerned are situated within the local limits of the Mandapam Panchayat Board. Prior to 1935 the "house" tax for these properties used to be levied by the Pamban Union and the appellant company was paying such taxes. Accordin