The petitioner as the managing trustee of the Iluppakudi devasthanam was convicted under rule 30(2) read with rule 36 of Chapter IV to the District Municipalities Act for wilful omission to pay the property tax due to the Karaikudi Municipality for the first half year 1944-45, amounting to Rs. 795-6-3, and sentenced to pay a fine of Rs. 10 or two days’ simple imprisonment in default. He was also directed to pay the property tax of Rs. 696-15-0. On appeal to the Sub-Divisional Magistrate of Devakottai, the conviction and sentence were confirmed.

The learned advocate for the petitioner raised several interesting points of law; but, I do not propose to express my opinion on any of those points, excepting one, namely, the point of limitation. This is because, admittedly, these points were not raised in the lower Courts and I consider that the points cannot be satisfactorily disposed of without further facts. It is common ground that there is another prosecution pending in respect of property tax due to the municipality for a subsequent period; and, in fact there is now before me an application, C.M.P. No. 1925 of 1946, to quash proceedings in S.T.C. No. 524 of 1946. It would be p