S.S.Sandhawalia, J.

1. The constitutional validity of Section 20(5) of the Punjab General Sales Tax Act is the sole issue that has been debated in this set of nineteen connected writ petitions.

2. As is manifest from the above, the question being pristinely legal, any reference to the facts is hardly of any relevance and it deserves notice that the Learned Counsel for the petitioner did not even remotely do so. However, to appreciate the contentions raised and noticed hereafter, it becomes necessary to recall albeit briefly the legislative history of the aforesaid provision.

3. When originally enacted on 20th November, 1948, the relevant part of Section 20 of the Punjab General Sales Tax Act read as follows:

20. Appeal.--(1) Within 60 days from the receipt of a notice issued under Sub-section (7) of Section 11 any dealer may in the prescribed manner appeal to such authority as may be prescribed against such assessment: Provided that no appeal shall be entertained by such authority unless he is satisfied that the amount of tax assessed on the dealer has been paid.

Later, by the East Punjab General Sales Tax (Amendment) Act, 1953, the rigour of the rule requiring the payment