JUDGMENT :

Sanju Panda, J.

1. The appellant by means of this Writ Appeal assails the judgment dated 18.04.2019 passed by the learned Single Judge in W.P.(C) No. 12841 of 2016, rejecting the Writ Application filed by the appellant.

2. The learned Single Judge vide judgment dated 18.04.2019 held that the demand of the registering authority is strictly in terms of the provision contained in Rule 2(f)(ii) of The Odisha Stamp Rules, 1952 and he has taken into consideration the decision of the Apex Court in the case of State of Haryana & Others Vs. Manoj Kumar reported in (2010) 4 SCC 350.

3. Learned counsel for the appellant submitted that the learned Single Judge did not appreciate the provision contemplated under Rule-2(f)(ii) in its proper perspective. Rule-2(f)(ii) of the Odisha Stamp Rules, 1952 mandates that the value of any property, which is the subject matter of conveyance, exchange, gift, partition or settlement by or on behalf of the Central Government or the State Government or any authority or body incorporated by or under any law for the time being in force 'as shown in the instrument'. He has further submitted that as per the said Rule, the Stamp Duty and Registration Fee is