Chang Min Tat FJ (delivering the judgment of the Court):

Chia Ah Kow alias Chia Siew Seng, the fourth-named appellant, is one of twenty-three purchasers in a housing-estate who are all dissatisfied with the adjudication of the Collector of Stamp Duties on the amounts of stamp duties to be paid on the transfers to them of the lands and houses built on them. In his case, the record of appeal gives the agreement of purchase, the transfer and the adjudication. The facts in the other cases vary somewhat from his and from one another, but only as to the details of the purchases. The question to be decided is a question of law which is common to all of them. It was and is sufficient merely to refer to the facts in the case of Chia Ah Kow. It would have been sufficient consequently if the appeal record was to consist of documents relating to his case only.

On 30 October 1971 Chia Ah Kow executed an agreement for the purchase of a plot of land, of not less than 1,600 square feet, on which a two-storeyed shop-house was to be erected by the developers, for the inclusive price of $49,000. On 4 July 1973, a transfer of the property agreed to be purchased into the name of Chia Ah Kow w