JUDGMENT Brijlal Gupta, J. - This is a writ petition under Article 226 of the Constitution of India. 2. The prayer contained in this petition is, that a writ of certiorari may be issued, quashing the orders dated 23-2-1954, 27-4-1955, 6-7-1956 and 28-2-1958, passed under the U.P. Agricultural Income-tax Act, the first two by the assessing authority, the next by the Commissioner in appeal, and the last, by the Agricultural Income-tax Board, in revision, in respect of the years 1360 and 1361-F. 3. The order of the Board is very cryptic and is to the following effect: "This revision application has been signed by the counsel and not by the assessee. This practice is irregular. For the reasons given in Revision No. 207 of 1957, District Rae Bareli Nirpal Singh v. State, 1958 ALJR (Rev.) 69 the application is incompetent and will be returned to the signatory concerned of the revision applications. This order would govern Revision Application Nos. 500 and 516 of 1956/District Bijnor." 4. The case referred to in this order has since been reported in Nirpal Singh v. State, 1958 ALJR (Rev.) 69. I have carefully examined that case. It appears to me, that the facts of that case were very different from the facts of the present case, and further in my view, that case was wrongly decided. I shall deal with it, at length, hereafter. 5. The facts of the present case, which have not been controverted, are, that the petitioner signed two Vakalatnamas, in favour of one Sri Jugul Kishore Sharma, a Vakil practising at Bijnor. The Vakalatnamas authorised Sri Jugul Kishore Sharma, to take all legal proceedings, and to do all necessary acts, in respect of any such legal proceeding, in the "court" of the Agricultural Income tax Board, Allahabad. It follows that under the Vakalatnamas, Sri Jugul Kishore Sharma had authority to sign revision applications also, on behalf of the petitioner, and which were to be filed before the Board. Acting on the authority of the Vakalatnamas, Sri Jugul Kishore Sharma duly prepared and signed revision applications, and filed them before the Board. In due course, the revision applications came up for hearing. Acting on the authority of the Vakalatnamas, Sri Jugul Kishore Sharma duly prepared and signed revision applications, and filed them before the Board. In due course, the revision applications came up for hearing. At the hearing, Sri Shanti Bhushan, an Advocate of this court, duly authorised by other Vakalatnamas, executed in his favour, appeared before the Board to argue the revisions, with the result, which is clearly indicated by the order of the Board, quoted above. 6. The short question, which has been raised, and which arises for decision is, whether the omission of the petitioner to sign the revision applications personally, and getting them signed on his behalf by Sri Jugul Kishore Sharma, authorised under the Vakalatnamas, executed in his favour, rendered the revision applications incompetent and unentertainable. 7. The requirements of the Act and the Rules may first be examined. Sec. 22 of the U.P. Agricultural Income Tax Act, which provides for revisions, only requires an application to be made to the Board, on which the Board may pass "such orders as they think fit." That section does not lay down, that the application has to be in any particular form, or that it has to be signed by the applicant himself, and not by any one else on his behalf. This is brought out more clearly, when the provisions in Section 22, are compared with the provisions in Section 21, which provides for appeals. Sub-Sec. (4) of Section 21 is to the following effect: "(4) Every appeal under this section shall be presented in the prescribed form and shall be verified in the prescribed manner." "Prescribed" has been defined in Sec. 2(12) and means "prescribed by rules made under this Act." Sec. 44 gives power to the State Government to make rules for carrying out the purposes of the Act. Sub-Sec. (2) (h) of Section 44, is to the following effect: "(2) In particular, and without prejudice to the generality of the foregoing power, such rules may - (h) prescribe the manner in which and the period, not being less than thirty days, within which appeal under Section 21 shall be filed and the manner in which the memorandum of appeal shall be verified." 8. In pursuance of these statutory provisions regarding appeals, R. 25 was framed by the State Government. In pursuance of these statutory provisions regarding appeals, R. 25 was framed by the State Government. This rule provides for a period of limitation for filing appeals, forms in which appeals are to be filed, and for verification of the memoranda of appeals. The three forms prescribed for appeals are forms Nos. A. I. T. 6, 7 and 8. These forms require to be signed at two places. Even though it is not stated, whether the signature is to be of the appellant himself, or can be of an authorised representative, on his behalf, yet, the form of verification provided in these forms of appeal, would seem to indicate that at least under the "form of verification," the signature of the appellant himself is required. But it is not necessary to decide this matter finally, in this case. 9. In the case of revisions, there is no such provision, either in the Act, as has already been seen above, or in the rules. No form of revision applications is prescribed under the Act. It follows that there is nothing in the Act or the rules to require an applicant, in a revision, to sign the revision application personally. Under the general law, and in accordance with the procedure of the highest courts, it is settled that any act, unless expressly required to be done personally, can be validly got done through another, so long as that other is duly authorised, to do that act. This is on the principle: qui facit per alium facit per se. It may be stated, that to a limited extent, this principle is countenanced by the U.P. Agricultural Income tax Act itself. Under Section 40, it is provided as follows :- "Any assessee, who is entitled or required to attend before any income tax authority in connection with any proceedings under this Act, may attend either in person or by any person authorised by him in writing in this behalf." One other provision, may also be noticed, in this connection. This provision is contained in R. 25-E, of the rules framed by the State Government. That rule originally ran as follows : "Revision petitions shall be presented in the Agricultural Income-tax form appended to Agricultural Income tax Rules, to the Collector of the district where the petitioner was assessed and the latter shall forward the same to the Board for disposal." 10. That rule originally ran as follows : "Revision petitions shall be presented in the Agricultural Income-tax form appended to Agricultural Income tax Rules, to the Collector of the district where the petitioner was assessed and the latter shall forward the same to the Board for disposal." 10. It appears, that no form for revision petitions was ever drawn up or appended to the Rules. The State Government appears to have noticed this anomaly in rule 25-E, and by, notification No. 406/I-C-326-C. 55, dated 24-9-1955 deleted the words: "in the Agricultural Income-tax form appended to Agricultural Income-tax Rules." from R. 25-E, which thereafter, stood in its amended form as follows: "Revision petitions shall be presented to the Collector of the district where the petitioner was assessed and the latter shall forward the same to the Board for disposal." 11. From this also, it follows, that if the intention of the legislature or the State Government was that revision applications should also be filed in any particular form, and should be signed by applicants personally, there was nothing to prevent them from making provision for the same, at least when the anomaly was noticed by them. Instead we find, that they deleted the requirement of the presentation of revision petitions in any particular form. In some of the other taxing statutes also, e.g., the Income Tax Act, and the U.P. Sales Tax Act, even though forms of appeal are prescribed, there is no form prescribed for revision applications. 12. Next, the question may be examined from another point of view. No Act or rules, however, detailed they might be, could possible make provision for every contingency that may arise. Accordingly, so far as procedure is concerned, we find provisions in various Acts and Rules made under them, that the court or tribunal, which is charged with the duty of administering the Act, may regulate its procedure. In the present case, such provision is made in R. 25-C. That Rule is to the following effect: "The Commissioner or the Additional Commissioner and the Board shall regulate the procedure of cases before them provided the same is not repugnant to the Act or the Rules and has been previously approved by the State Government." Under this rule, the Board has undoubtedly been given the power to regulate the procedure of Cases before it. This power, however, is subject to two limitations: (i) that the procedure which is the result of such regulation by the Board shall not be repugnant to the Act or the Rules; and (ii) that such procedure shall have been previously approved by the State Government. 13. If in the regulation of procedure of revision applications before it, the Board have made it obligatory, that revision applications should be in any particular form, or that they should be signed personally by the applicants in revisions, then in the absence of any specific provision in the Act or the Rules, in this behalf, it was necessary for the Board, to have obtained the prior approval of the State Government, in regard to such procedure. It is well known, that the acts of the State Government, are expressed to be done in the name of the Governor, and are evidenced by notifications published in the Gazette. Sri N.D. Pant, learned Junior Standing Counsel, who appeared for the respondents, in this case, could not bring to my notice, any notification according the approval of the State Government to such procedure. It follows that the procedure adopted by the Board, in requiring revision applications to conform to any particular form or to be signed personally by the applicants in revision applications, is without the authority of law. 14. The reasons, of the requirements, in R. 25-C, are obvious. If the regulation of procedure in cases before the Board or other authorities mentioned in that rule, was left to their sole discretion, there might be variation in that procedure, consequent upon the change of personnel of those authorities, and uniformity and certainty of procedure would be destroyed. There could also be any publicity of such procedure, as there is, when procedure is approved and expressed by the State Government, by publication in the Gazette. This would naturally lead to hardship and injustice. A prior approval by the State Government also provides, a safeguard against the exercise of discretion arbitrarily. Even in the case of rules framed by the State Government, a further safeguard is always provided by the statute; as for example, here, in sub-sec. This would naturally lead to hardship and injustice. A prior approval by the State Government also provides, a safeguard against the exercise of discretion arbitrarily. Even in the case of rules framed by the State Government, a further safeguard is always provided by the statute; as for example, here, in sub-sec. (3) of Section 44, which is to the following effect: - "All rules made in this section shall be laid for not less than seven days before the Provincial Legislature as soon as possible after they are made and shall be subject to such modification as the Legislature may make during the session in which they are so laid." 15. Thus the rule making powers of even the State Government, are not untrammelled and uncontrolled. Therefore, it was only right that regulation of procedure by the various authorities, mentioned in R. 25-C should be, after prior approval of the State Government. 16. Then there is the other limitation, namely, that the procedure of cases regulated by the Board shall not be repugnant to the Act or the rules. It is true that there is no provision therein, forbidding that on applicant in revision shall not be required to sign a revision petition personally, but from what has been stated above, and particularly having regard to the difference in procedure between an appeal and a revision, it seems to me, that it was not the intention of the legislature, that an applicant in revision should be required to sign a revision application personally, or that a revision application should be in any particular form. From this it appears to me, that if according to the procedure of revisions regulated by the Board, it is required by the Board, that revision applications will be signed personally by the applicants therein, or that the revision applications shall be in the same form as appeals, this procedure would be repugnant to the provisions of the Act and the rules, and would be invalid. I may state that repugnancy results, not merely from contravention of expression provisions, but also from contravention of the intention of the legislature even though not expressed, but which can be gathered from the provisions of the Act. I may state that repugnancy results, not merely from contravention of expression provisions, but also from contravention of the intention of the legislature even though not expressed, but which can be gathered from the provisions of the Act. I am supported in this view by a decision of Channel, J. in Gentel v. Rapps, 1902(1) KB 160 as below: "A bye-law is repugnant where it purports to prohibit something which the general law either expressly or by necessary implication declares lawful. The byelaw would be none the less repugnant because the provision which it had contradicted was only implied." This decision was quoted with approval by Lord Hewart, C. J. in L. M. S. Railway v. Griever, 1937 (1) KB 367. 17. I now proceed to consider the decision of the Board in Nirpal Singh's case, 1958 ALJR (Rev.) 69, upon which, the Board relied in deciding the revision application, in this case. The facts of the case were, that one Sri Ram Kishun Srivastava, an Advocate practising in the Board of Revenue signed a revision application under a which was headed "In the Hon'ble Board of Revenue, Allahabad." On one of the preliminary dates of hearing of the revision application, the applicant in revision in that case, was also allowed to sign the revision application, subject to objection on behalf of the State. The Board took the view that the "Agricultural Income-tax Board" was a different Tribunal from the "Board of Revenue." Accordingly, the Vakalatnama executed in favour of the Advocate, authorising him to appear before the "Board of Revenue," was not an authorisation, to enable that counsel, on the strength of that Vakalatnama, to appear before the "Agricultural Income-tax Board." On this ground it held, that the signature of Sri Ram Kishun Srivastava on the revision petition, was by a person, who was not authorised to sign the memorandum of revision, which was to be filed in the Agricultural Income-tax Board. The Board also took the view, that Sri Ram Kishun Srivastava, was not entitled to sign the revision application merely by reason of his right as an Advocate, under Section 4 of the Legal Practitioners Act, to practice in all courts, subordinate to the High Court and in all revenue offices. The Board also took the view, that Sri Ram Kishun Srivastava, was not entitled to sign the revision application merely by reason of his right as an Advocate, under Section 4 of the Legal Practitioners Act, to practice in all courts, subordinate to the High Court and in all revenue offices. The Board held that the Agricultural Income-tax Board was not a "Court", but a tribunal, and further that it was not a "revenue office" as defined in Section 3 of that Act. As regards the signature, which the applicant was subsequently allowed to make on the revision application, subject to objection at the final hearing, the Board took the view, that such permission would not be correct. It observed: "If an assessee does not take proper care to conform to the rules he must bear the consequences. In the case of appeals a form has been prescribed by the rule making authority under the Act. It has been the "settled view" of this Board that revision applications must confirm to the pattern of appeals. In this connection Maharaj Kumar Kamal Singh v. State, AIT Rev. No. 143, D/d. 18.12.1957, is relevant." The summing up of their findings, so far as the same are material for the purposes of this case, was as follows:- "We hold that Revision No. 201 (Nirpal Singh's, 1958 ALJR (Rev.) 69) was not properly presented inasmuch as it was neither signed by the assessee, nor by a person authorised by the assessee to appear before the Agricultural Income-tax Revision Board . . . . . and lastly this is not a fit case in which the assessee should be permitted to regularise the defect at this stage." In the result the Board ordered, that the revision application be returned to the signatory concerned. 18. It will at once be observed, that the facts of Nirpal Singh's case, 1958 ALJR (Rev.) 69 were very different from the facts of the present case. There, the advocate in question, who had signed the revision application, was not authorised to appear before the Agricultural Income-tax Board. Here, there was no such defect in the authorisation, and the lawyer in this case, was expressly authorised to act in the revision before the Agricultural Income-tax Board. There, the advocate in question, who had signed the revision application, was not authorised to appear before the Agricultural Income-tax Board. Here, there was no such defect in the authorisation, and the lawyer in this case, was expressly authorised to act in the revision before the Agricultural Income-tax Board. Accordingly, the finding in that case, that the revision application was not signed by a person, authorised by the assessee to appear before the Agricultural Income-tax Revision Board, did not apply in this case. The summing up by the Board, would also seem to indicate that what was intended by the Board only was, that where a lawyer was not authorised to act before the Board, he could not properly sign a revision application on behalf of the applicant, because as seen in the summing up, one of the findings on the basis of which they returned Nirpal Singh's application was, that it was not signed by a person, authorised to appear before the Agricultural Income-tax Revision Board. From this it would seem to follow, that if it had been signed by a person, authorised to appear before that Board, the application may not have been liable to be returned. 19. Another finding, which the Board recorded, in disposing of Nirpal Singh's case, 1958 ALJR (Rev.) 69 was: "if an assessee does not take proper care to conform to the rules he must bear the consequences." Sri N.D. Pant, learned counsel for the State has not been able to show to me what "rules", if any, the Board referred to in this passage from their judgment. It has already been seen, that there is no such rule under the Act. If the rules referred to in the passage are some rules of practice framed by the Board, they do not appear to have been published, and it has not been shown, that the approval of the State Government was obtained to any such rules. If the "settled view" of the Board mentioned in one of the above quotations from their decision is referred to by them as the rules, it is a misnomer. A "view", however, "settled" cannot be called a rule, or have the force of a rule. If the "settled view" of the Board mentioned in one of the above quotations from their decision is referred to by them as the rules, it is a misnomer. A "view", however, "settled" cannot be called a rule, or have the force of a rule. It can, at best, be described only as procedure, regulated by the Board, and the conditions precedent for such procedure being valid, and of its having the force of law, have already been dealt with above. Sri N.D. Pant has not been able to show to me that the condition precedent for the validity of such procedure, namely, that a revision application must be signed by a petitioner has been satisfied. It follows, that the procedure, requiring a petitioner to sign a revision application personally and which the Board described as a "rule" or a "settled view" is not warranted by the law and is, therefore, illegal. 20. At this place, I should also like to observe, that procedure is merely a machinery for the enforcement of legal rights. The right of revision given to a person under the U.P. Agricultural Income-tax Act is a valuable right. The exercise of that right is not fettered by the Act, except that the right shall be exercisable by means of an application, and within a certain time. To fetter that right, by requiring a petitioner to sign the application personally, contrary to the Act and to the general law, is to restrict that right very much. To my mind restriction of the right of revision, in this way, under the guise of the right to regulate procedure, was wrong and it cut down that right seriously. It was held nearly two centuries ago, in the well known case of Kendall v. Hamilton, 1878 (4) AC 525 that procedure was merely machinery, and its object was to facilitate, and not to obstruct the administration of justice. 21. What appears to me to be much more objectionable in the decision in Nirpal Singh's case, 1958 ALJR (Rev.) 69 is, that even though Nirpal Singh was allowed to sign the application subsequently in an attempt to regularise the "irregularity," the Board held that it would not be correct to permit such subsequent regularisation. It was not that authority to the contrary was not brought to the notice of the Board, by the counsel for the petitioner in that case. It was not that authority to the contrary was not brought to the notice of the Board, by the counsel for the petitioner in that case. Decisions both of the Supreme Court and of this Court, were cited before the Board. These decisions were: the decision of the Supreme Court reported in Jagannath v. Jaswant Singh, A.I.R. 1954 SC 210 in which it was laid down, "that even where the law confers an authority on a tribunal to proceed with a petition in accordance with certain procedure, but when it does not state the consequences of non-compliance with that procedure, the jurisdiction of the tribunal to proceed with the case is not affected." It. was further laid down that "non-compliance relating to the impleading of parties was not necessarily fatal and could be cured." It follows that in the absence of statutory provision, requiring an applicant to sign a revision petition, and further in the absence of any penal consequence for such omission, the Board should have proceeded with the petition after getting the omission, if any, rectified. 22. The other decision of the Supreme Court was, Pratap Singh v. Sri Krishna Gupta and others, A.I.R. 1956 SC 140 in which it was observed: "We deprecate this tendency towards technicality; it is the substance that counts and must take precedence over mere form. Some rules are vital and go to the root of the matter; they cannot be broken; others are only directory and a breach of them can be overlooked provided there is substantial compliance with the rules read as whole and provided no prejudice ensues; and when the legislature does not itself state which is which, judges must determine the matter and, exercising a nice discrimination, sort out one class from the other along broad based, commonsense lines." 23. Any one could at once see, that the omission to sign a revision application, was a matter, which did not go to the root, and was merely a matter of procedure, particularly when the Act or the Rules did not require such signatures. Article 141 of the Constitution lays down, that the law declared by the Supreme Court shall be binding on all courts within the territory of India. It is very surprising that the Board should have made no attempt to grapple with that law and as stated in paras. Article 141 of the Constitution lays down, that the law declared by the Supreme Court shall be binding on all courts within the territory of India. It is very surprising that the Board should have made no attempt to grapple with that law and as stated in paras. 12 to 18 of their own decision, in Nirpal Singh's case, 1958 ALJR (Rev.) 69 and should have completely ignored it. 24. The matter did not rest there. Two decisions of this Court also were cited before the Board. The first one is reported in Bombay Baroda and Central India Rly. Company Ltd. v. Sivaji Mills Co. Ltd., A.I.R. 1927 Alld. 514 decided by a Bench presided over by that great Judge and jurist, Sir Shah Mohammad Sulaiman in which, it was laid down, on the authority of an old Full Bench decision of this Court, that "any irregularity in the signature or verification is a mere defect of procedure, and cannot be fatal, when the merits of the case have not been affected. The best that can happen would be to call upon the plaintiff to get the plaint signed against and verified . . . . such a small irregularity does not affect the merits or the jurisdiction." 25. The other case is a Full Bench decision of this Court, reported in Wali Mohammad Khan v. Ishak Ali Khan, A.I.R. 1931 Alld. 507 : 1931 ALJ 777. In this case also, the Full Bench was presided over by Sir Shah Mohammad Sulaiman. In this case, it was laid down "the absence of signatures or verification does not affect the jurisdiction of the court, and the suit must be deemed to have been duly instituted on their behalf, if it was filed with their knowledge and authority The omission to comply with a provision like this would be a mere irregularity and not an absence of jurisdiction . . . . . If the plaintiff has acted in good faith and without gross negligence and it is fair and just to allow the defect to be cured, the court would undoubtedly do so." 26. The two Allahabad cases were under the C.P.C., which requires a plaint to be signed and verified by the plaintiff. Even in such a case, it was held that any irregularity in such a matter, was trial and should be allowed to be cured. The two Allahabad cases were under the C.P.C., which requires a plaint to be signed and verified by the plaintiff. Even in such a case, it was held that any irregularity in such a matter, was trial and should be allowed to be cured. In the case of a revision before the Board, there was no such legal requirement. It follows that the Board should have the more readily allowed the petitioner in Nirpal Singh's case, 1958 ALJR (Rev.) 69 to sign the revision application subsequently, and thus cure the defect, if it can at all be called a defect, and which was so merely, on account of what they described as their "settled view." 27. The Board completely ignored these two cases also, and made no attempt to discuss the observations quoted above from those cases. It may be that the Agricultural Income-tax Board is not a court or tribunal subordinate to this Court, in the same sense, in which a civil court is. The fact, however, remains that under Section 24, a reference lies to this Court, from the order of the Board on revision, and the order of the Board is subject to the result of the reference, and further the Board is required to dispose of the case in accordance with the opinion of this Court on such reference. Article 227 of the Constitution also invests this Court with the power of Superintendence over all court and tribunals throughout the territory of this State. This power is both administrative and judicial. From this it follows, that the Board could not, with propriety, ignore the decisions of this Court, and refuse to be guided by them, even though, they were pointedly brought to their notice, by counsel for the petitioner in Nirpal Singh's case, 1937 I K.B. 367 (376). It is an elementary principle of judicial propriety, that inferior courts and tribunals should seek guidance and draw inspiration from decisions of superior courts. 28. The only case, out of the large number of cases, which were cited before the Board, and to which the Board at all applied their mind, was the decision of the Madras High Court in V. S. P. Subramanian Chettiar v. Commissioner of Income-tax Madras, 1953 (24) ITR 89 . 28. The only case, out of the large number of cases, which were cited before the Board, and to which the Board at all applied their mind, was the decision of the Madras High Court in V. S. P. Subramanian Chettiar v. Commissioner of Income-tax Madras, 1953 (24) ITR 89 . In that case it was held inter alia that an authority given to an Advocate under a Vakalatnama did not terminate with the decision of appeal before the Income-tax Appellate Tribunal, but continued to be in force. The Board considered only this part of that decision in para. 15 of their judgment in Nirpal Singh's, 1937 (1) KB 367(376). To my mind this part of the Madras decision, was wholly irrelevant, to the point at issue before the Board, in that case. Sri N. D. Pant learned counsel for the State did not find it possible to support the decision in Nirpal Singh's case, 1937 (1) KB 367(376) on any ground whatsover. 29. There are one or two other aspects of the decision of the Board, to which I must advert, before I part with that case. 30. It has been noticed that the signature of an applicant was not legally required on a revision application, and the signature of a duly authorised agent on his behalf was sufficient. Even if the Board wanted the petition to bear the applicant's signature, they should have allowed him to sign it subsequently. This would be a very minor amendment to cure a mere irregularity. The law on the subject of amendment of pleadings, as has been laid down by high authority is as follows: 31. In Tildesley v. Harper, 1878 (10) CD 393 it has been observed by Bramwell, L. J. as follows:- "As a general rule, leave to amend will be granted so as to enable the real question in issue between the parties to be raised on the pleadings, where the amendment will occasion no injury to the opposite party, except such as can be sufficiently compensated for by costs or other terms to be imposed by the order. I have had much to do in Chambers with applications for leave to amend, and I may perhaps be allowed to say that this humble branch of learning is very familiar to me. I have had much to do in Chambers with applications for leave to amend, and I may perhaps be allowed to say that this humble branch of learning is very familiar to me. My practice has always been to give leave to amend unless I have been satisfied that the party applying was acting mala fide or that, by his blunder, he had done some injury to his opponent which could not be compensated for by costs or otherwise. It does not matter that the original omission arose from negligence or carelessness." In Clarapede & Co. v. Commercial Union Association, 1883 (32) WR (Eng.) 262, it was observed as follows: "However negligent or careless may have been the first omission, and, however, late the proposed amendment, the amendment should be allowed if it can be made without injustice to the other side. There is no injustice if the other side can be compensated by costs." In Cropper v. Smith, 1884 (26) CD 700 Bowen, L. J. observed as follows:- "that there is one panacea which heals every sore in litigation, and that is costs. It is immaterial whether the error sought to be amended was accidental or not. There is no rule limiting amendment to accidental errors. The rule says all such amendments shall be made as may be necessary for the purpose of determining the real questions in controversy." It was also observed in this case: "There is no kind of error or mistake which, if not fraudulent or intended to overreach, the Court ought not to correct if it can be done without injustice to the other party." 32. It follows that the Board were in error, not only in insisting, on the personal signature of an applicant on a revision application, but in persisting in their refusal to allow, what they imagined to be an irregularity, to be cured. One may only hope, that during the years, that the Board have exercised revisional jurisdiction in Agricultural Income tax matters, too much injustice has not been done, and too many parties not deprived of the valuable remedy of revision, which the statute gave to them. 33. Towards the end of their judgment, the Board permitted them-selves to indulge in a general observation, in para. 33. Towards the end of their judgment, the Board permitted them-selves to indulge in a general observation, in para. 18 of their judgment, at page 73 of the report: "We are painfully aware that assessees have been abusing the processes provided to them under the Agricultural Income-tax for the purposes of delay. It is in some cases their effort to go on making applications after applications from one authority to another merely with the object of delaying the finalisation of those cases." Under the Act, there is a hierarchy of authorities appellate, revisional, and the High Court. If the legislature thought that before a tax liability should be allowed to become final, it should be sifted by several authorities, it was not for an authority, charged with the administration of the Act, to object to assessees having recourse to those authorities. The filing of an appeal or a revision under the Act, does not automatically result in stay of the realisation of tax. Thus if assessees exercise the valuable rights of appeal, revision or reference to superior authorities, it is in the discretion of superior authorities, to allow or not allow the tax demand to be kept in abeyance. This is all that the authorities should be concerned with. In any case, litigants can always be penalised for delaying tactics, but a general observation like the one made by the Board, is something extraneous, which should not have been allowed to influence their decision, in a particular case. In the end I shall only make two more observations: (1) It is not possible for me to understand how the Board could cut down, the amplitude of their revisional powers to act suo motu, and to confine the same to the four cases, which they have set out in para. 17 of their judgment at page 73. It is not necessary for me for, the purposes of the present writ petition, to deal with this point at any length: (2) I have also not been able to understand, what legal basis there is, for the Board to return to an applicant, a revision application, not signed by him personally. To my mind, upon the view, which the Board took of the matter, they could only reject the application. For the reasons stated above, this writ petition must be allowed. To my mind, upon the view, which the Board took of the matter, they could only reject the application. For the reasons stated above, this writ petition must be allowed. A writ of certiorari shall issue quashing the order of the Board dated 28-2-58. The revision applications Nos. 575 and 516 of 1956 shall be treated as standing restored to the file of the Agricultural Income tax Board, and shall be taken up by the Board for hearing, and be disposed of according to law, in the light of the revisional powers contained in Section 22 of the U.P. Agricultural Income-tax Act. The petitioner shall be entitled to his costs of the petition.