By the Court.—We have heard Shri A.D. Saunders, learned counsel for the petitioner. Learned Standing Counsel appears for the State respondents. Shri Afzal Beg appears for the Allahabad Jal Sansthan, Allahabad, which is now known as Nagar Nigam, Allahabad.

2. This writ petition is directed against the demand of water tax for the year 2009-10 of Rs. 3,61,025/-, at 12 1/2% of the annual value of the building, assessed by the Nagar Nigam, Allahabad for the house tax at Rs. 21,87,800/-.

3. Brief facts giving rise to this writ petition are as follows :

“There is an institution known as Boys’ High School & College, Allahabad. The institution imparts education up to Class XII and is affiliated to the ICSE.

There is a church known as ‘Holy Trinity Church, Allahabad’ for Christians’ worship. Alongwith the church building there was open land of the church. On the campus of the church there is a hall known as ‘Knox Hall’. This hall stands independently and is used for church’s religious activities. Till date this hall is used for church activities as and when required.

Boys’ High School & College which had been established in the year 1860 required an additional annexe as the admission