JUDGMENT-The application arises out of a tax appeal in respect of the .immovable property owned by the respondent and filed against the Municipal Corporation of Sholapur City. Originally this area was governed by the Bombay Municipal Boroughs Act, 1925. This municipality was converted into a Corporation on May 1, 1964. Prior to that date, for the purposes of assessing rate able value, notices were issued under section 81 (1) of the above Act on February 10, 1964, to various owners of immovable properties. Objections were filed as required by the Act and in the present case objections of the opponent were heard on February 14, 1964. The appellate authority ultimately rejected these objections. Thereafter, after the municipality became a Corporation, a bill for the tax due from the opponent came to be issued on June 29, 1964, for the year 1964-65. The opponent deposited the amount of the tax and filed an appeal in terms of section 406 of the Bombay Provincial Municipal Corporations Act, 1949. The Municipal Corporation contended that as the assessment was made under the Municipal Boroughs Act, 1925 and objections were also disposed of under the same Act, an appeal should lie not to the Civil Judge as provided under section 406 of the Bombay Provincial Municipal Corporations Act, but to a Judicial Magistrate as provided under section 110 of the Municipal Boroughs Act, 1925. The learned Civil Judge under section 410 of the Bombay Provincial Municipal Corporations Act, 1949, made a reference to the District Judge for his decision on this question. The learned District Judge held that the appeal was rightly filed before the learned Civil Judge, Senior Division, under section 406 of this Act and directed that the appeal should be heard on merit. Against this judgment, the Municipal Corporation comes to this Court. 2. One must be surprised that on such a point as this the learned Civil Judge should have referred the matter to the learned District Judge. I have been referred by Mr. Kadam to section 410 of the Rombay Provincial Municipal Corporations Act, which provides for a reference. The section is: "410. 2. One must be surprised that on such a point as this the learned Civil Judge should have referred the matter to the learned District Judge. I have been referred by Mr. Kadam to section 410 of the Rombay Provincial Municipal Corporations Act, which provides for a reference. The section is: "410. If, before of on the healing of an appeal relating to the rate able value or tax, any question of law or usage having the force of law, or the construction of a document arises, the Judge may and, on the application of any party to the appeal shall draw up a statement of the facts of the case and the question so arising and refer the statement with his own opinion on the point for the decision of the District Court". 3. A Civil Judge, Senior Division, in all civil matters has unlimited jurisdiction. He decides important as well as unimportant questions of law as well as questions of usage having the force of law under the Civil Procedure Code, only when a question of interpretation of constitutional Jaw arises that he is required to make 8; reference to the High Court. Under Order XLVI also it is rarely that a Civil Judge makes a reference to a superior Court. The, section permits the Judge on his own to make a reference if he so chooses. If this were so, there would have been no difficulty in the matter. But the Legislature has provided that he shall draw up a statement of facts and refel the point with his own opinion for the decision of the District Court on the application of any party to the proceedings. One should have thought that such a provision would be hardly necessary when the matters are beard by a Civil Judge, Senior Division, who decide such questions every day. The only effect of this provision would appear to be that one or the other of the parties may by requiring the learned Judge to make a reference in this manner prolong the matter unduly. After all the decision of the learned Civil Judge is not binding since an appeal is provided to the District Court against the decision of the Civil Judge. After all the decision of the learned Civil Judge is not binding since an appeal is provided to the District Court against the decision of the Civil Judge. Whatever that may be, one may only hope that at least the Civil Judges will not make references to the District Court merely as a1 matter of course on their own. At least that will save a great deal of litigation. 4. Coming to the question of jurisdiction, I have no doubt that t¥ learned District Judge was right in taking the view that an appeal lies under, section 406 of the Bombay Provincial Municipal Corporations Act, 1949 and, must be heard and disposed of by the Civil Judge. Section 490 of this Act: provides that the Bombay District Municipal Act, 1901, the Bombay Municipals Boroughs Act" 1925. shall cease to apply, except as hereinafter provided, to any area included in the city. The provisions referred to are those mention in section 493 and those in Appendix IV of the Act, which are very important. Clause 2 provides that all the rights of the municipality or any other local authority for the area which has been constituted to be a City shall on the appointed day vest in the Corporation constituted for the said area ... Clause 3 provides that all sums that are due to, the said Municipality shall be recoverable by be the Commissioner for the, city and he would, be competent to take any measures or institute any proceedings which could have been open, to the authority of the said municipality or local authority to take or institute, if the Act had not come into operation and the area had not been constituted the be a city. Clause 4 is corollary to clause 3 and it, provides that as debts and obligations and, all contracts which were made on behalf of such municipal or local authority and which were subsisting on the said day shall, be deemed to have been concurred made by the Commissioner for the city in the exercise of the powers conferred an him by the Act. Similarly, it further provides that all proceedings pending before any authority, of the municipality, or any local authority, which were instituted before, shall be transferred and continued before the Commissioner before such authority aalis entitled to, disposer them of under, the present Act., Even in respect of appeals pending before and authority of the Corporation, it is provided that the same shall be disposed oft as far its practicable as iii the area was constituted to be a city when they were file? It is in the light of these provisions that have can not to construe clause 5 which refers to appointment, notification etc. which were in force prior to the forming of the Corporation of this area. Sub-clause (b) is relevant and it reads as follows: "( b) all budget estimates, assessments, valuations , measurements , and divisional made under the Bombay District Municipal, Boroughs Act, 1925, or any other law in force in any are constituted to be city immediately before the appointed day shall in so far as they are constitution to be city immediately before the appointed day shall in so far as they are constituent with the provisions of this Act, be deemed to have been made under this Act.” Reading these provisions along with clause 3, it is clear that the notice of demand which was issued on June 29, 1964, must be deemed to have been issued under the provisions of the Act, and once I come to this conclusion, there can be 110 gainsaying that an appeal must lie under section 406 of this Act. In this connection, it must also be remembered that at the time of the filing of the appeal, there was no Municipality of Sholapur in existence and the Municipal Boroughs Act did not apply. 5. In my view, therefore, the learned Judge was fully justified in the view that he has taken. Reject. Civil Revision Applications No 8. 280 and 281 of 1966. 6. These applications arise out of appeals filed by the opponents before the learned Civil Judge, Senior Division, at Sholapur. In this case also he made a reference to the District Court. The question involved here was whether the appeals could be heard when the opponents had paid only one installment of tax. 280 and 281 of 1966. 6. These applications arise out of appeals filed by the opponents before the learned Civil Judge, Senior Division, at Sholapur. In this case also he made a reference to the District Court. The question involved here was whether the appeals could be heard when the opponents had paid only one installment of tax. The learned District Judge in both cases held that the opponents were not hound to pay the whole amount claimed in the bill, deposit of only one installment being sufficient compliance within the meaning of section 406 (2) (e) of the Act. Expressing this opinion, he returned the matters to the learned Civil Judge, Senior Division. 7. Appeal is provided under this Act by section 406. Sub-section (2) is relevant and it is as follows: "406. (2) No such appeal shall be heard unless- . (e) in the case of an appeal against a tax, or in the case of an appeal made against a rate able value after a bill for any property tax assessed upon such value has been presented to the appellant, the amount claimed from the appellant has been deposited by him with the Commissioner." The other provision which must be noticed is one of the rules relating to the taxation prescribed in Chapter VIII under section 453 of the Act, and it (Rule 30) is as follows: "3(). Each of the property-taxes shall be payable in advance in half-yearly installments on each first day of April and each first day of October." The question is whether the payment of one installment before the hearing of the appeal means payment of "the amount claimed from the appellant." The provisions of a statute must be interpreted reaE10nably and in their ordinary sense, unless the words used are words of special meaning, in which case they may have larger or smaller meaning. The provision is not that no appeal shall be heard unless the tax due is paid, but that no appeal shall be heard unless the said amount is paid. Merely because an appeal is filed, one fails to see why the party concerned should not be required to pay the whole amount of the tax. Very often, hearing of appeal takes considerable time and even the second installment may become due. Merely because an appeal is filed, one fails to see why the party concerned should not be required to pay the whole amount of the tax. Very often, hearing of appeal takes considerable time and even the second installment may become due. It would be unduly restricting the meaning of the words "the amount claimed from the appellant," if the qualification that the appellant should pay only one instalment of tax is introduced in the section. Inasmuch as there is no possible injustice in requiring the opponents to deposit the full amount of tax, I do not see why this strained construction of the section should be adopted when the words are simple and when the section itself does not contain any qualification whatsoever. 8. In my view, the opinion of the learned District Judge is not correct. The respondent has to pay the second instalment which is long overdue. 9. However this maybe, this does not mean that this Court is bound to interfere with the order of the Court below in revisional jurisdiction whiu4 is a very limited jurisdiction. I, therefore, reject these two applications also. Applications rejected.