1. The question raised in this Civil Revision Petition is whether under Article 1 of Schedule I of the Court-Fees Act as amended a court-fee is payable on the equitable set-off claimed by the defendant in the suit. The principal Subordinate Judge of Devakottai held that a court-fee was payable tentatively. The matter thus comes before us. We are quite unable to see why in reason a written statement or a defence pleading a legal set-off should have to bear a court-fee and one pleading an equitable set-off not be liable to do so also. In the former case the set-off pleaded may be of a very small amount and in the latter case of a very large amount, It is conceded by Mr. Patanjali Sastri that beyond what he suggests as a technicality no reason can possibly be advanced for this distinction between the two classes of set-off. An equitable set-off is a legally recognised one and we fail to see why any distinction should be drawn between that and a legal set-off. The matter is somewhat bare of authority. So far as this High Court is concerned, the only decision since the amendment of the Court-Fees Act is the decision of Sundaram Chetty, J., in Sitarama Aiyar v. Ramanuja Mudaliar