JUDGMENT :

Gaurang Kanth, J. 

1. The Petitioner has instituted the present writ petition seeking a declaration that Section 3 of the Kolkata Municipal Corporation (Amendment) Act, 2022, by which Section 179(2)(d) of the Kolkata Municipal Corporation Act, 1980 has been substituted, is unconstitutional and ultra vires the Constitution of India. The Petitioner has further sought quashing of the letter dated 23.07.2024 issued by the Respondent Corporation, whereby a demand of Rs. 11,24,27,669/-, along with a penalty of Rs. 39,40,847.22/-, has been raised towards alleged arrears of property tax in respect of various parts and portions of the basement, the 11^th floor, part of the 12^th floor, and the 13th to 16th floors of Premises No. 8, Camac Street (now Abanindranath Thakur Sarani), Kolkata.

2. The facts leading to the present case are as follows:

3. The Petitioner No. 1 is a Charitable Society established in 1981 under the Societies Registration Act, 1860. Petitioner No. 2 is a trustee of Petitioner No. 1.

4. At the relevant time, i.e., in 1984, Petitioner No. 1 was the owner of the basement, the 11th floor, part of the 12th floor, and the entirety of the 13th to 16^th floors of a building