Supreme Court of India
COMMISSIONER OF WEALTH TAXversusM/S. SHRAVAN KUMAR SWARUP AND SONS, ETC. ETC.
- Citation
- 1994 INSC 411
- Decided
- 22 September 1994
- Disposal
- Dismissed
- Bench
- M N VENKATACHALIAH
Holding
Rule 1BB is a procedural rule of evidence and therefore applies to pending proceedings, including assessment years prior to its commencement.
Summary
The assessee, a Hindu Undivided Family, challenged the valuation of its residential properties for the assessment years 1977-78 and 1978-79, contending that Rule 1BB of the Wealth Tax Rules, 1957 (effective 1 April 1979) should be applied even though the assessments were made after the rule’s introduction. The Revenue argued that Rule 1BB was substantive and could not be applied retrospectively to assessment years preceding its commencement. The High Court and lower tribunals held that the rule was applicable, prompting the Revenue to appeal to the Supreme Court. The Court examined whether Rule 1BB is a substantive provision affecting rights or a procedural rule of evidence, and whether it binds pending proceedings. It concluded that Rule 1BB is essentially a procedural rule of evidence intended to ensure uniform valuation and therefore may be applied to cases pending at its enactment. Consequently, the appeals filed by the Revenue were dismissed.
Issues considered
- Whether Rule 1BB of the Wealth Tax Rules, 1957 is a substantive provision or a procedural rule of evidence.
- Whether Rule 1BB, introduced on 1 April 1979, is applicable retrospectively to assessment years 1977-78 and 1978-79.
Legislation cited
- Wealth Tax Act, 1957s. 27(1), s. 2(m), s. 2(q), s. 3, s. 4, s. 46, s. 5, s. 6, s. 7
Subjects
Wealth TaxRule 1BBValuation of propertyProcedural lawRule of evidenceRetrospective applicationHindu Undivided FamilyTax assessment
Judgment
A COMMISSIONER OF WEALTH TAX
v.
MJS. SHRAVAN KUMAR SWARUP AND SONS, ETC. ETC.
SEPTEMBER 22, 1994
B
(M.N. VENKATACHALIAH, CJ, S.C. AGRAWAL, J.] :
Wealth Tax Rules 1957, Rule lBB-Whether it affects the substantive
rights of the assessee or is merely procedural-Whether the Rules partakes of
C the character of a mle of evidenc~Whether the said mle lBB applies to all
proceedings pending its enactment.
The 'Respondent assessee was a Hindu Undivided family. For the
assessment years 1977-78 and 1978-79 the assessments were made on
8.2.1983. Before that date rule lBB had been introduced into the Rules on
D 1.4.1979 which provided the tnode of valuation of house property wholly or
mainly used for residential purposes, for the purpose of ascertaing that
net wealth under the Wealth Tax Act, 1957. The assessee contended that
immovable properties should be valued by applying the said Rule on even
though the assessments in question pertained to the period prior to
1.4.1979. The Wealth Tax Officer proceeded to value the properties inde·
E pendently of Rule lBB, The Commissioner of Wealth Tax (Appeals) held
in favour of the applicability of Rule lBB.
On appeal by the Revenue before the Income Tax Tribunal, Ah·
medabad, the Tribunal upheld the Order of the Commissioner of Wealth
F Tax (Appeals). Thereafter, the Revenue sought a reference under Sec. 27(1)
of the Wealth Tax Act in respect of both the assessment years. The
Tribunal referred for the opinion of the High Court the question whether
Rule lBB could be applied to compute the value the properties for the
relevant assessment years though Rule l·BB came into force from April 1,
1979 only. The High Court, following its earlier decision in commissioner
G of Wealth Tax v. Shri Kasturbhai Mayabhai, 164 ITR 107, answered the
question against the Revenue and held that Rule lBB was applicable. In
the appeal filed by the Revenue against the said decision the question
raised was whether Rule l·BB is a provision which affects or alters the
substantive rights or it is merely a procedure. Further, sequential question
H that was raised was whether Rule 1-BB is attracted to all proceedings
750
COMMNR. OFW.T. v. S.KSWARUP AND SONS 751
pending at its enactment. These questions also fell for consideration in a A
number of appeals and special leave petitions which were all heard
together.
... Dismissing the appeals and special leave petitions, this Court
HELD: 1. Rule lBB of the Wealth Tax Rules merely provides a choice B
amongst well-known and well-settled modes of valuation. Even in the
absence of Rule lBB it would not have been objectionable, nor would there
have been a legal impediment to adopt the mode of valuation embodied in
it, namely the method of capitalising of income on a number of years'
purchase value. The Rule was intended to impart uniformity in valuations C
and to avoid vagaries and disparities resulting from application of dif·
ferent modes of valuation. [760-F]
2. Rule lBB thus partakes of the character of a rule of evidence. It
deems the market value to be the one arrived at on the application of a
particular method of valuation which is also one of the recognised and D
accepted methods. [760-G]
3. Rule lBB, being essentially a rule of evidence is procedural in
nature. A procedural law, generally speaking, is difficult to pending cases
since no similar case be said to have a vested right in procedure. [761-C-D]
E
Commissioner of Wealth Tax v. Shri Kasturbhai, 164 ITR 107; Com-
missioner of Wealth Tax v. Naranjan Narottam, 173 ITR 693; Commissioner
of Wealth Tax v. Vidyawathi Kapur, 150 ITR 319; Commissioner of Wealth
Tax v. Lacchmandas Bhatia, 163 ITR 586; Commissioner of Wealth Tax v.
O.P. Tandon, 195 ITR 688:Manjushri Biswas v. CWT, 171 ITR348 andDilip
Kr. Mitra v. CWT, 200 ITR 336, approved. F
Izhar Ahmed Khan v. Union of India, [1962) Supp. 3 SCR 235;
Kesoram Industries v. CWT, 59 ITR 767; Murari Lal Mahabir Prasad & others
v. B.R. Ved & others, 37 STC 77;Associated Cement Compariy Ltd. v. CT01
Kota, 48 STC 466; Jose Da Costa v. Bascora Sadasiva Sinai Narcornim & G
others, [1976) 2 sec 917, relied upon.
Maxwell v. Murphy (1957) 96 CLR 261; Republic of Costa Rica v.
Elanger, (1876) 3 ChD 62; WH. Cockerline & Co. v. CIR 16 TC 1; Halsbury's
Laws of England, 4th Edn.; Vol. 23, para 29 and Vol. 44, para 925; Black's
Law Dictionary, 6th Edn. p. 1203; Salmond in Jurispmdence, 12th Edn. p. H
)
' \
.752 SUPREME COURT REPORTS [1994) SUPP. 3 S.C.R.
A 462 and Bennion's Statutory Inte1pretation, First Edn., page 446, para 191,
referred to.
CIVIL APPELLATE JURISDICTION: Civil Appeal Nos. 6367-68
of 1994 etc. etc.
B From the Judgment and Order dated 31.7.89 of the Allahabad High
Court in'. W.T.A. No. 106 of 1989
J. Ramamurti, B.B. Ahuja, Manoj Arora, S. Rajappa, Ranbir
Chandra, D.S. Mehra, Parmeswaran, B.K. Prasad and Ms. A. Subhashini
for the· Appellant.
c
Raja Ram Agrawal, G.Sarangan, Harish N. Salve, Praveen Kumar,
Virender Kaushal, Triburari Ray, Vineet Kumar, Yashank Adhyaru, AP.
Medh, Ms. Deepa Dixit and K.J. John for the Respondents.
The Judgment of the Court was delivered by /.
D
VENKATACHALIAH, CJ. In these appeals and special leave peti-
tions brought up by the Revenue the short but interesting question that
arises is whether Rule lBB of the Wealth Tax Rules, 1957 is a provision
which affects and alters the substantive rights or is merely procedural. The
E further sequential and cognate question is whether the Rule is attracted to
ail proceedings pending at its enactment. The said rule lBB concerns the ,
mode of valuation of house-property wholly or mainly used for residential
purposes, for the purposes of ascertaining the net wealth·under the Wealth
Tax Act. 1957.
F 2. Section 3 of the Wealth Tax Act is the charging section. It seeks
to bring to charge for every assessment year the net wealth on. the cor-
responding valuation date of every individual, Hindu undivided family and
company. The expression "net wealth" is defined in Section 2(m) of the Act.
Section 2(q) defines the "valuation date". Section 4 enumerates the assets
G to be included in computing 'net-wealth'. Sections 5 and 6 exempts certain
assets in India and outside from being included in computing the net ...
/
wealth.
3. Section 7 - and this provision is of particular relevance here -
speaks as to how the va!ue of the assets has to be determined. Section 7(1),
H as it stood during the relevant period, i.e., prior to 1.4.1989 when it stood
COMMNR. OFW.T. v. S.K SWARUP AND SONS (VENKATACHALIAH, CJ.] 753
substituted by the Direct Tax Laws (Amendment) Act, 1989 with effect A
from 1.4.1989 provided:
"7(1) : Subject to any Rules made in this behalf the value of any
asset other than case, for the purposes of this Act, shall be
estimated to be the price which in the opinion of the Wealth Tax
Officer it would fetch if sold in the open market on the valuation B
date."
The Central Board of Revenue in pursuance of the rule making
power conferred by Section 46 of the Act promulgated rules known as the
Wealth Tax Rules 1957. These were amended from time to time and Rule C
1-BB - with which we are now concerned - came to be inserted by the
Wealth Tax (Amendment) Rules, 1979 with effect from 1.4.1979. The
relevant part of the Rule reads as under :
"lBB(l) for the purpose of sub-section (1) of section 7, the value
of a house. which is wholly or mainly used for residential purposes D
shall be the aggregate of the following amounts, namely :
(a) The amount arrived at by multiplying the net maintainable rent
in respect of the part of the house used for residential purposes
by the fraction 100/8; and
(b) the amount arrived at by multiplying the net maintainable rent E
in respect of the remaining part of the house, if any, by the fraction
100/9.
Provided that in relation to a -house which'is built on leasehold
land, this sub rule shall have effect, as if for the fraction 100/8 in F
clause (a), or as the case may be, the fraction of 100/9 in clause
(b), the fraction 100/9 and 100/10 respectively had been sub-
stituted."
Sub-rule (2) (a) defines the expression "Gross Maintainable Rent";
sub-rule (2)(b) defines as "House" including an independent residential G
unit and Sub-rule (2)(c) the expression "Net Maintainable Rent".
Sub-rule(S), however envisages a departure from the regime of sub-
rule (1} and provides that where the Wealth Tax Officer, having regard to
the facts and circumstances of the case, is of the opinion that it is not
practicable to apply the provisions of Rule to such a case, he may apply H
754 . SUPREME COURT REPORTS [1994] SUPP. 3S.C.R.
A the rule with the previous approval of the Inspecting Assistant Commis-
sioner.
4. The principal question in these cases is whether this Rule is a
provision of substantive law, not expressly rendered applicable to the
valuation for the earlier years, and, therefore, only prospective or whether
B it is merely procedural attracted to all pending cases.
We have heard Sri J. Ramamurti, learned senior counsel for the
Revenue and Sri Raja Ram, Agrawal and Sri G. Sarangan, Learned senior
counsel for the assessees.
c In some of the cases in this batch, there are some delays in filing
them. We condone the delays. We grant special leave in the special leave
petitions.
5. We may here refer to the facts of Civil Appeals Nos. 3563-64 of
D 1993 which are representative of the batch. The Commissioner of Wealth
Tax, Gujarat-IV, Ahmedabad assails the correctness of the judgment and
order dated 21.12.1989 of the Gujarat High Court in Wealth Tax Reference
No. 15of1987. The assessment years are 1977-78and1978-79 respectively.
Assessments were made on 8.2.1983 by which time Rule lBB had been
introduced into the rules. The assessee, a Hindu Undivided Family, con-
E tends that its immovable properties be valued applying the said Rule lBB
even though the assessments in question pertain to the orders prior to
1.4.1979 on which date the said rule came into force. The Wealth Tax
Officer rejected this claim and proceeded to value the immovable proper-
ties independently of this said Rules lBB. The appeals preferred by the
F assessee before the Commissioner of Wealth Tax (Appeals) were allowed
and the Appellate Authority held in favour of the applicability of Rule lBB.
The appeals of the Revenue before the Income Tax Appellate Tribunal,
Ahmedabad were unsuccessful. The Tribunal upheld the Commissioner of
Wealth Tax (Appeals). The Revenue sought a reference under Section
G 27(1) of the Wealth Tax Act in respect of both the assessment years. The
Tribunal referred the following question .of law for the opinion of the High
Court:
''Whether, in law and on facts the Appellate Tribunal is right in
directing the Wealth Tax Officer to compute the value of
H Shalnbagh Bungalow under Rule lBB of the Wealth Tax Rules,
COM:MNR OFW.T. v. S.K. SWARUP AND SONS [VENKATACHAUAH, CT.) 755
1957 specially when the said rules came into effect from 1.4.1979 A
only?"
The High Court answered the question against the Revenue following its
earlier decision in Commissioner of J.l'.ealth TOJ1. v. Shri Kasturbhai Mayab-
-· hai, 164 ITR 107. The High Court having declined to certify the case as
one fit for appeal to the Supreme Court, the Revenue has come up by
special leave to appeal.
B
InKasturbhai Mayabhai's case (supra), the High Court had taken the
following view :
"There is, therefore, no doubt that while Section 3 is the charging C
section, the machinery for the purpose of computing the net wealth
is provided in Section 7 of the Act.
xxxxxxx
Pursuant thereto Rule lBB came to be introduced in the Rules D
providing a formula for the determination of the fair market value
of a house used wholly· or mainly for the purpose of residence. It
became necessary for the Board to provide a formula for deter-
mining the market value of a house in order to speed-up the
disposal of cases involving questions of valuation of such an asset. E
xxxxxxx
Since Section 7(1) is a machinery Section and since the rule to
be made under Section 46(2) must relate to the manner in which
the market value of any asset may be determined, it can be safely F
inferred that the rule making authority can lay down the method
or mode of determining the market value of each asset. When a
rule sets out the method for formula for determining the market
value of any particular asset, it can only be considered to be
procedural and not substantive .. Rule lBB with which we are
concerned also lays down the formula for determining the market G
value of a house used wholly or mainly for residence. Since the
rule provides a formula or mechanical method of valuation, it is
difficult to agree with learned counsel for the Revenue that it is
substantive in character. It has not the effect of impairing any
vested right or creating any new obligation; ...... " H
756 SUPREME COURT REPORTS [1994) SUPP. 3 S.C.R.
A Again in Commissioner of Wealth Tax v. Naranjan Narottam, 173
ITR 693, the Gujarat High Court followed the Kasturbhai Mayabhai's case
(supra). The decision of the High Court in Kasturbhai Mayabhai's case is
also under appeal in the present batch of appeals.
Similar view has been taken by the Karnataka High Court in Com-
B missioner of Wealth Tax, Kamataka, Bangalore v. Vidyawathi Kapur, 150
ITR 319; Madhya Pradesh High Court in Commissioner of Wealth Tax v.
Lacchmandas Bhatia, (163) ITR 586; Delhi High Court in Commissioner
of Wealth Tax v. 0.P. Tandon & Ors., (195) ITR 688; the Calcutta High
Court in Smt. Manjushri Biswas v. Commissioner of Wealth Tax, (171) ITR
C 348 and Dilip Kumar Mitra v. Commissioner of Wealth Tax, (200) ITR 336.
6. The basis of distinction between statutes affecting rights and those
affecting merely procedure is well-recognised. Dixon, CJ. in Maxwell v.
Murphy, (1957) 96 CLR 261 at 267 drawing upon the following words of
Lord Justice Mellish in Republic of Costa Rica v. Erlanger, 1876 (3) Ch.D.
D 62 at 69 said :
"No suitor has any vested interest in the course of procedure, nor
any right to complain, if during the litigation the procedure is
changed, provided, of course, that no injustice is done."
J~
It is true that if one traces any substantive right back far enough it will be
found secreted in the interstices of procedure.
In W.H. Cockerline & Company v. The Commissioner of Inland
Revenue, (16) TC 1 at 19, Lord Hanworth quoted with approval a following
F pa&sage from the judgment of Sargent, L.J.:
"The liability is imposed by the charging Section, namely, Section
38 the words of which are clear. The subsequent provisions as to
assessment and so on are machinery only. They enable the liability .
to be quantified and when quantified to be enforced against the
G subject, but the liability is definitely and finally created by the
charging section and all the materials for ascertaining it are avail-
able immediately."
In Halsbury's Law of England (Fourth Edn. Vol. 23, Para 29), refer-
H ring to the machinery provisions it is stated :
COMMNR. OFW.T. v. S.K. SWARUP AND SONS (VENKATACHALIAH, CJ.) 757
"It is important to distinguish between charging provisions, which A
impose the charge to tax, and machinery provisions, which provide
the machinery for the quantification of the charge and the levying
and collection of the tax in respect of the charge so imposed.
Machinery provisions do not impose a charge or extend or restrict
·~
a charge elsewhere clearly imposed."
B
The distinction between substantive law and. procedural provisions
has been indicated in Black's Law Dictionary, (Sixth Edn. P. 1203) as
follows:
"As a General Rule, laws which fix duties, established rights and C
responsibilities among and for persons, natural or otherwise, are
'Substantive Laws' in character, while those which merely prescribe
the manner in which such rights and responsibilities may be exer-
cised and enforce in a court are 'Procedural Laws"
In Salmond's Jurisprudence, (Twelth Edn. P. 462), the distinction D
between substantive law and law of procedure is indicated in the following
words:
"What, then, is the true nature of the distinction? The law of
procedure may be defined as that branch of the law which governs
the process of litigation. It is the law of actions -- jus quod ad E
actions pertinet -- using the term action in a wide sense to include
all legal proceedings, civil or criminal. All the residue is substantive
law, and relates, not to the process of litigation, but to its purposes
and subject-matters. Substantive law is concerned with the ends·
which the administration of justice seeks' procedural law deals with F
the means and instruments by which those ends are to be attained.
The latter regulates the conduct and relations of courts and
litigants in respect of the litigation itself; the former determines
their conduct and relations in respect of the matters litigated."
".........What facts constitute a wrong is determined by ~he substan- G
tive law; what facts constitute proof of a wrong is a question of
procedure."
".......... So far as the administration of justice is concerned with the
application of remedies to violated rights, we may say that the
substantive law defines the remedy and the right, while the law of H
758 SUPREME COURT REPORTS (1994) SUPP. 3 S.C.R.
A procedure crefines the modes and conditions of the application of
the one to the others."
In Izhar Ahmad Khan v. Union of India, (1962) Suppl. 3 SCR 235 at
251 it is observed:
B "The division of law into two broad categories of substantive la'Y
and procepural law is well known. Broadly stated, whereas sub-
stantive law defines and provides for rights, duties, liabilities, it is
the function of the procedural law to deal with the application of
substantive law to particular ~ases and it goes without saying that
the law of Evidence is a part of the law of procedure." ·
c
In Kesoram Industries and Cotton Mills Ltd. v. Commissioner of
Wealth Tax (Central), Calcutta, (59) IT~ 767 at 793 Justice Shah observed:
"Section 7(2) merely provides machinery in certain special cases
from valuation of assets, and it is from the aggregate 'valuation of
D
assets that the net wealth. chargeable to tax may be ascer-
tained............... This is an artificial rule adopted with a view to
avoid investigation of a mass of evidence which it w9uld be
difficult to secure or, if secured, may require prolonged investiga-
tion."
E
Though this was a part of the minority·opinion, there is, however, nothing
said to the contra in the majority view.
In Murari Lal Mahabir Prasad & Ors. v. B.R. Vad & Ors., (37) STC
77 at 111, this Court laid down as follows.:
F
"We are concerned in this case to determine not whether a par-
ticular turnover can be brought to sales tax but whether if the
turnover was liable to be charged to sales· tax, the firm can be
assessed to tax after its dissolution. In other words, we are con-
cerned with a provision which prescribes the machinery for the
G
computation of tax and not with a charging provision of the Sale
· TaxActs."
7. Procedural law, generally speaking, is applicable to pending cases.
No suitor can be said to have a vested right in procedure. It must, however,
H be noted that a provision can be partly substantive and partly procedural.
COMMNR OFW.T. v. SK. SWARUP AND SONS [VENKATACHALIAH, CJ.] 759
InAssoCiated Cement Company ltd. v. Commercial Tax Officer, Kota A
& Ors., (48) STC 466 at 476 this Court laid down:
''It is settled law that a distinction has to be made by Courts while
interpreting the provisions of a taxing statute between charging
provisions which impose the charge to tax and machinery
provisions which provide the machinery for the quantification of B
the tax and the levying and collection of the tax so imposed. While
charging provisions are construed strictly, machinery sections are
not generally subject to .a rigorous construction. The courts are
expected to construe the machinery sections in such a manner that
a charge to tax is not defeated." C
Bennion's Statutory Interpretation, (First Edn. P. 446 para 191), lays
down as follows :
"Because a charge made by the Legislator in procedural provisions
is excepted to be for the general benefit of litigants and others, it D
is presumed that it applies to pending as well as future proceed-
ings."
At page 447 it is stated :
"Procedure and practice is the mere machinery of law enforcement. E
As Ormrod L.J. said :
'The object of all procedural Rules is to enable justice to be
done between the parties consistently with the public
interest'."
F
In Jose Da Costa &Anr. v. Bascora Sadasiva Sinui Nar.comim & Ors,
[1976) 2 SCC 917 at 925, this Court laid down as follows :
"Before ascertaining the effect of the enactments aforesaid passed
by the Central Legislature on pending suits, or appeals, it would
be appropriate to bear in mind two well established principles. The G
first is that while provisions of a statute dealing merely with matters
of procedure may properly, unless that construction be textually
inadmissible, have retrospective effect attributed to them
provisions which touch a right·in existence at the passing of the
statute are not to be applied retrospectively in the absence of H
760 SUPREME COURT REPORTS (1994] SUPP. 3 S.C.R.
A eXpress enactment or necessary intendment (See Delhi Cloth and
General Mills Co. Ltd. v. Income Tax Commissioner, (1927) P.C.
242).
The second is that a right of appeal being a substantive right
the institution of a suit carries with it the implication that all
B successive appeals available under the law then in force would be
preserved to the parties to the suit throughout the rest of the career
of the suit. There are two exceptions to the application of this Rule,
viz., (i) when the competent enactment such right of appeal is taken
away expressly or inipliedly with retrospective effect; and (ii) when
c the court to which appeal lay at the commencement of the suit
stands abolished (See Grikapati Ve"aya v. N. Subbiah Choudhary,
[1957] SCR 488 and Colonial Sugar Refinery Co. Ltd. v. Irving, 1905
AC 369)."
Halsbury's Laws of England (Fourth Edn. Vol. 44 Para 925) states:
D
"The presumption against retrospection does not apply to legisla-
tion concerned merely with matters of procedure or of evidence;
on the contrary, provisions of that nature are to be construed as
retrospective unless there is a clear indication that such was not
the intention of Parliament."
E
8. We may now turn to the scope and content of Rule 1BB. The said
Rule merely provides a choice amongst well-known and well-settled modes
of valuation. Even in the absence of Rule 1BB it would not have have been
objectionable, nor would there be any legal impediment, to adopt the mode
F of valuation embodied in Rule 1BB namely, the method of capitalisation
of income on a number of years' purchase value. The rule was intended to
inipart uniformity in valuations and to avoid vagaries and disparities result-
ing from application of different modes of valuation in different cases
where the nature of the property is similar.
G Rule 1BB thus partakes of the character of a rule of evidence. It
deems the market value to be the one arrived at on the application of a
particular method of valuation which is also one of the recognised and
accepted methods. Even if a law raises a presumption and renders the
presumption irrebuttable it is yet in the domain of the law of evidence. In
H Izhar Ahmad Khan's case (supra), it was pointed out by this Court:
COMMNR OFW.T. v. S.K. SWARUP AND SONS (VENKATACHALIAH, CJ.] 761
"It would be noticed that as in the case of a rebuttable presumption, A
so in the case of a irrebuttable presumption, the rule purports to
assist the judicial mind in appreciating the existence of fact. In one
case the probative value is statutorily strengthened but yet left open
to rebuttal, in the other case, it is statutorily strengthened and
placed beyond the pale of rebuttal. Considered from this point of B
view, it seems rather difficult to accept the theory that whereas a
rebuttable presumption is within the domain of the law of evidence,
irrebuttable presumption is outside the domain of that law and
forms part of the Substantive Law."
9. On a consideration of the matter we are persuaded to the view C
that Rule lBB is essentially a rule of evidence as to the choice of one of
the well accepted methods of evaluation in respect of certain kinds of
properties with a view to achieving uniformity in valuation and avoiding
disparate valuations resulting from application of different methods of ·
valuation respecting properties of a similar nature and character. Tlie view
taken by the High Courts, in our opinion, cannot be said to be erroneous. D
The appeals are accordingly dismissed. There will, however. be no
order as to costs.
S.K. Appeals and petitions dismissed.
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