JUDGMENT M. H. Beg, J. - The petitioner under Article 226 of the Constitution seeks a writ of certiorari to quash an order of the Commissioner, Rohilkhand Division, Bareilly passed on 16-8-1963. The order purports to deal with two review applications filed under Section 138 of the U. P. Kshettra Samitis and Zila Parishad Adhiniyam (hereinafter referred to as the Adhiniyam). This section reads as follows : "Bar to jurisdiction of civil and criminal court in matters of taxation :- (1) No objection shall be taken to a valuation or assessment nor shall the liability of a person to be assessed or taxed be questioned in any other manner or by any other authority than is provided by or under this Act. (2) The order of the appellate authority confirming, setting aside or modifying an order in respect of calculation or assessment or liability to assessment or taxation shall be final. Provided that it shall be lawful for the appellate authority, upon application or on his own motion to review any order passed by him in appeal by further order passed within three months from the date of his original order." 2. The learned Commissioner, surprisingly, allowed the two review applications of the Antarim Zila Parishad, Moradabad, opposite party No. 4, and set aside the order of the Additional District Magistrate (Judicial) opposite party No. 2 passed on 16-11-1962 on an appeal under Section 128 of the U. P. District Boards Act, which was re-pealed by Section 274 of the Adhiniyam. 3. It is not disputed that under Section 128 of the District Boards Act an appeal lay to the District Magistrate -which could be properly dealt with by the Opposite Party No. 2 if the District Boards Act had not been repealed. The petitioner had filed an appeal on 14-5-1962 with regard to an assessment of tax on circumstances and property for 1960-61, passed by the Tax Officer of the Antarim Zila Parishad on 12-4-1962, of which the demand notice was served on petitioner on 14-4-1962. The Additional District Magistrate (Judicial) had allowed the appeal and remanded the case for further enquiry to the Tax Officer. It is against the order of the Additional District Magistrate, passed in appeal on 16-11-1962, that the Antarim Zila Parishad, opposite party. No. 4, had filed two review applications before the Commissioner. It is not clear why two applications were filed. It is against the order of the Additional District Magistrate, passed in appeal on 16-11-1962, that the Antarim Zila Parishad, opposite party. No. 4, had filed two review applications before the Commissioner. It is not clear why two applications were filed. No provision could be shown under which such an application could be filed before the Commissioner. 4. The Commissioner proceeded on the assumption that, after the repeal of the U. P. District Boards Act, no appeal could be decided by the Additional District Magistrate under the U. P. District Boards Act. The Commissioner also thought that Section 128 of the Adhiniyam had the effect of barring the jurisdiction of the Additional District Magistrate. The learned Commissioner was completely oblivious of the existence of Section 6 of the U. P. General Clauses Act which gives the effect of a repeal of a U. P. Act. Section 6 (e) makes it clear that such a repeal will not "affect any remedy, or any investigation or legal proceedings commenced before the repealing Act shall have come into operation in respect of any such right, privilege, obligation, liability, penalty, forfeiture or punishment as aforesaid, and any such remedy may be enforced and any such investigation or legal proceedings may be continued and concluded, and any such penalty, forfeiture or punishment imposed as if the repealing Act had not been passed." 5. The Adhiniyam had come into force by notification on 18-7-1962. Therefore, it could not affect the jurisdiction at all of the Additional District M'agistrate to decide the appeal pending before him. Section 138 of the Adhiniyam did not confer any jurisdiction upon the learned Commissioner at all to deal with such a case. There was no question of any review application before him as the learned Commissioner had not passed any previous order upon the case. Section 138 only bars the jurisdiction of civil and criminal court in matters of taxation by Zila Parishads. It has nothing to do with the jurisdiction of the special authority set up under the U. P. District Boards Act or the Adhiniyam to deal with an assessment of tax. I am afraid the learned Commissioner completely misunderstood the meaning of Section 138 of the Adhiniyam. The Commissioner had no jurisdiction whatsoever to pass the order he made on 16-8-1963. That order is a nullity. I am afraid the learned Commissioner completely misunderstood the meaning of Section 138 of the Adhiniyam. The Commissioner had no jurisdiction whatsoever to pass the order he made on 16-8-1963. That order is a nullity. I, however, hereby quash it, as it may be used to the prejudice of the petitioner. The petitioner is entitled to his costs from the contesting opposite party No. 4, the Antarim Zila Parishad of Moradabad.